New England Interstate
Water Pollution Control
                     116 John Street
                     Lowell, Massachusetts
Bulletin 62
A Report On Federal & State Programs To Control Leaking Underground Storage Tanks
     The term "sustainability" is
     widely used, but like beauty,
     its meaning is very much in
the eye of the beholder. At its core, sus-
tainability seeks to achieve a qualitative
improvement in the human condition
such that we are maintaining the ecologi-
cal capacity of the Earth to support life
(Daly, 1996). Within this context, each of
us as beholders can define sustainability
to suit our own preferences. For example,
many people equate sustainability
with efforts to reduce greenhouse gas
(GHG) emissions to stem global cli-
mate change. But, we can also have  /
sustainable fanning practices that  [I
seek to maintain the health of the soil
and its environs for the long term.
   Sustainability comprises eco-
nomic, social, and ecological objectives,
the so-called "pillars" of sustainability,
and all three must be met concurrently in order to achieve sustain-
able outcomes. Because sustainability is all-encompassing, no single
program can possibly address all of its varied aspects. Those of us
in federal, state, tribal, and local UST programs need to answer the
question of what sustainability means in the context of our programs.
And then we must ask: What can we do to make meaningful progress
toward achieving sustainable tank programs?
                                                 Sustainability as
                                                 Environmental Policy
                                                 Federal and state UST programs are often
                                                 operationally constrained by resources and
                                           ^^   have limits with respect to their regulatory
                                                authorities. Nowhere in the federal authoriz-
                                              ing statute or regulations is it explicitly stated
                                             that the UST program must consider sustainability
                                           in program implementation. However, the National
                                           Environmental Policy Act (NEPA) of 1969 implicitly
                                           extends responsibility for consideration of sustain-
                                          ability to all federal departments and agencies in coop-
                                          eration  with state and local governments and other
                                          stakeholders. NEPA requires the "use [of] all practicable
                                          means and measures, including financial and technical
                                                                 • continued on page 2
                                          (.  5U USEPA to Develop a Green Cleanup Standard
                                          (  6() Transient Behavior of Water in Ethanol-Blended Fuels
                                          (  8() What If Methanol...?
                                          ( 12() Biodiesel Multimedia Evaluation Case Study
                                          ( 14() Another Spill-Prevention Device
                                          ( 16() Stage I Vapor Recovery Coming to a Station Near You
                                          ( 19() Recommended Practice for Marina Fueling Systems
                                          ( 20() Energy Policy Act Strengthens Prevention Programs
                                          ( 21Q Hydraulic Conductivity/Low-Flow Sampling
                                          ( 22Q A Short History of the NWGLDE
                                          ( 24() Class C Operator Training Online

LUSTLine Bulletin 62 • August 2009
m Tank Programs and
Sustainability from page 1

assistance, in a manner calculated to
foster and promote the general wel-
fare, to create and maintain condi-
tions under which man and nature
can exist in productive harmony, and
fulfill the social, economic, and other
requirements of present and future
generations of Americans."
    In  1993, USEPA published  a
report  to Congress entitled Sustain-
able Development and the Environmen-
tal Protection Agency. In  setting the
stage for  future sustainable devel-
opment policy, this report cites con-
sensus on three fundamental tenets.
First, the adoption of a long-term
perspective; second, the interdepen-
dence of the economy and the envi-
ronment;  and third, the  creation of
new integrative approaches. Though
this report establishes broad policy
goals, responsibility for meeting spe-
cific objectives is left to the individ-
ual program offices.
    In  2005,  USEPA launched  a
"stewardship" initiative that assimi-
lated and refocused the Agency's

           EUen Frye, Editor
          Ricki Pappo, Layout
     Marcel Moreau, Technical Adviser
    Patricia Ellis, PhD, Technical Adviser
 Ronald Poltak, NEIWPCC Executive Director
    Deb Steckley, USEPA Project Officer
 LUSTLine is a product of the New England
 Interstate Water Pollution Control Commis-
  sion (NEIWPCC). It is produced through
 cooperative agreements (US-83384301 and
 US-83384401) between NEIWPCC and the
   U.S. Environmental Protection Agency.
   LUSTLine is issued as a communication
      service for the Subtitle I RCRA
   Hazardous & Solid Waste Amendments
       rule promulgation process.
     LUSTLine is produced to promote
 information exchange on UST/ LUST issues.
 The opinions and information stated herein
  are those of the authors and do not neces-
   sarily reflect the opinions of NEIWPCC.
     This publication may be copied.
     Please give credit to NEIWPCC.
   NEIWPCC was established by an Act of
   Congress in 1947 and remains the old-
  est agency in the Northeast United States
 concerned with coordination of the multi-
      media environmental activities
    of the states of Connecticut, Maine,
     Massachusetts, New Hampshire,
   New York, Rhode Island, and Vermont.

            116 John Street
        LoweU, MA 01852-1124
        Telephone: (978) 323-7929
          Fax: (978) 323-7919
    *& LUSTLine is printed on recycled paper
prior sustainability efforts. The blue-
print for this initiative is described
in Everyday Choices: Opportunities for
Environmental Stewardship, which
defines stewardship as a: "respon-
sibility for environmental quality
shared by all those whose actions
affect the environment, reflected as
both a value and a practice by indi-
viduals, companies, communities,
and government organizations." This
initiative relies heavily on voluntary
approaches to achieve environmental
outcomes for six "natural resources
[that] are each part of a larger, life-
sustaining system": air, ecosystems,
energy, land,  materials, and  water
(USEPA, 2005).
    Complementing USEPA's efforts
to prevent pollution and promote
environmental stewardship are its
efforts to develop and promote the
use of green cleanup approaches to
restore sites to productive (re)use.
In some cases, conventional  reme-
diation efforts may create as much
or more pollution than they remedi-
ate (Forbes, 2009). In contrast, green
cleanups strive to minimize the envi-
ronmental footprint (USEPA, 2008a).

Opportunities for Sustainable
So, how do we define what "sustain-
ability" means in the context of the
UST program?  Appreciating that
there are many individual "behold-
ers" (states, tribes, and territories,
plus USEPA),  developing a consen-
sus definition has the hallmark of
an involved and protracted under-
taking. In the meantime, what can
UST programs do to make meaning-
ful progress toward sustainability
if we don't know what it means? To
get started, let's accept that sustain-
ability is a concurrent achievement
of economic, social, and ecological
net benefits. With this in mind, we'll
then identify opportunities for sus-
tainable practices in each of USEPA's
six priority areas within the steward-
ship framework discussed earlier.
    As if the concept of sustain-
ability wasn't protean enough, the
environmental impacts of  sustain-
able practices can be  either  direct
or indirect. For  example, reduced
electricity consumption associated
with "green"  buildings and  green
cleanups is a direct energy impact,
while  the reduced generation of
GHGs resulting from reduced elec-
tricity consumption is an indirect air
impact. We must also remember that
our UST programs are operationally
constrained. Hence, while we  can
directly influence practices such as
leak detection, we can only indirectly
influence practices such as construct-
ing a green gas station.

• Air  With regard to UST programs,
  air quality sustainable practices are
  primarily indirect. For example, a
  typical gasoline refueling facility
  consumes a considerable amount
  of electricity, the majority of which
  is generated by coal combustion.
  So a facility owner could opt to
  reduce the  amount of electricity
  consumed by constructing a green
  building (e.g., LEED certified) or
  using green technologies. A LUST
  program could promote the  use
  of sustainable site-remediation
  technologies (e.g., use of alterna-
  tive energy sources such as solar
  or wind-powered equipment; see
  Dellens, 2007; EPA, 2007a,c). Such
  measures would lead to reductions
  in emissions of GHGs, mercury,
  and oxides of sulfur and nitrogen.
  A reduction in energy consump-
  tion would also  have a financial
  incentive for  a  facility owner.
  Green gas stations are beginning to
  appear; a recently opened facility
  in Lawrence, Kansas, is intended
  to demonstrate the energy- and
  pollution-reduction benefits as an
  example for construction of future
  stations (Pomes, 2008).

• Ecosystems  The primary pur-
  pose of the UST program is to
  protect drinking water resources
  for human health and the environ-
  ment. Only in rare circumstances
  are  ecosystem impacts directly
  UST-related. Small surface spills
  that take place  during  vehicle
  refueling may result in situations
  where stormwater runoff washes
  contaminants into surface-water
  bodies, impacting aquatic  biota.
  Various Low Impact Development
  (LID) techniques  can be employed
  to reduce pollutant  (and  sedi-
  ment) loading of aquatic ecosys-
  tems (EPA, 2000a, 2007c).

  The cleanup and reuse ("revital-
  ization") of  abandoned UST facili-
  ties  can result in both direct and
  indirect positive impacts. Direct
  impacts would include  such

                                                                                August 2009 • LUSTLine Bulletin 62
  actions as converting an aban-
  doned urban gas station into a
  green space that serves as a park
  or playground, creating a micro-
  habitat for insects such as butter-
  flies or birds, simply reusing a site
  as a gas station, or developing a
  site for new housing, commercial,
  business,  or public facility  use.
  The indirect impact of such reuses
  is that construction on a pristine
  piece of property  in  an unde-
  veloped area has been avoided
  (USEPA, 2004).

• Energy  Opportunities for reduc-
  tion in energy consumption in
  the UST program lie chiefly with
  more efficient use  of  electric-
  ity, especially through the use of
  green UST  facilities and green
  cleanup technologies. At present,
  only a few UST facilities employ
  such technologies, but these may
  serve as demonstration projects
  to encourage broader participa-
  tion (see  USEPA, 2009a, pp.14-
  15; Pomes, 2008). Green  cleanup
  technologies have been used suc-
  cessfully at a number of nonpe-
  troleum remediation sites. (See
  Dellens,  2007;  USEPA, 2007a,
  2007b, 2008a.)

• Land  Many former gas  sta-
  tion properties, including a large
  number of abandoned gas station
  sites, offer direct opportunities for
  sustainable reuse of land, espe-
  cially within the context of smart
  growth. The UST program has
  developed a comprehensive plan
  for addressing these sites in the
  publication U.S. EPA's Petroleum
  Brownfields  Action Plan:  Promot-
  ing Revitalization and Sustainability
  (EPA, 2008b). Former UST sites
  have been reused as commercial
  and business establishments, pub-
  lic facilities, housing, and a vari-
  ety of other environmental and
  recreational purposes. Some of
  the successes of this program are
  highlighted in the UST program's
  recent 25th anniversary report.
  (See USEPA, 2009a, pp.6-7.)

  The UST program has also part-
  nered with  the Wildlife Habitat
  Council to  create parks, green
  space, and habitat from these sites.
  (See EPA, 2004.) Most of these sites
  are relatively small. Typical gas
  stations are on the order of an acre
or less, though truck stops may
be as much as two or three acres.
Although these sites are small,
there are many of them, and their
reuse as an alternative to devel-
oping pristine land in an unde-
veloped area can be significant in
preserving wildlife habitat.

Materials  Federal regulations
stipulate that UST systems be con-
structed of materials that are com-
patible with the substances stored.
Beyond this, there is no  stipula-
tion as to whether or not system
components  are  produced in a
sustainable manner. If we were to
take the notion of  sustainability to
the next life-cycle step, we could
envision USEPA negotiating with
equipment manufacturers  and

      comprises economic,

      social, and ecological

 objectives, the so-called "pillars"

of sustainability, and all three must

   be met concurrently in order

      to achieve sustainable


even setting up  public-private
partnerships to foster produc-
tion of UST-system components
in a sustainable fashion, but with
such a relatively small niche mar-
ket, participation would need be
entirely voluntary.
Taking this life-cycle  approach
requires an analysis for each com-
ponent. While not impossible, it
would be time-consuming  and
expensive and the results uncer-
tain. Proper economic incentives
would have to be developed in
order to convince manufacturers
and station owners that the effort
was worthwhile. In some instances
it may be possible to reuse/ recycle
debris from remediation activities
(e.g., excavated soil, pulverized
concrete and asphalt).
Water The  dwindling availabil-
ity of potable water supplies has
become a global issue.  Given the
toxicity and other noxious charac-
  teristics of most substances stored
  in USTs, even small releases can
  render vast quantities of ground-
  water or surface water unfit to
  drink. The UST program imple-
  ments a dual approach to ground-
  water protection. The first is
  pollution prevention and the sec-
  ond is rapid cleanup of pollution
  that does occur. Despite the pro-
  gram's efforts at preventing spills,
  overfills, and chronic releases,
  39  states still identify leaking
  UST systems among their  top ten
  threats to groundwater (USEPA,

  Many UST cleanups involve
  pumping contaminated ground-
  water, treating it (either above or
  below ground), and then reinject-
  ing the treated water back into the
  subsurface. Optimizing pumping
  systems so they are more hydrau-
  lically efficient, and hence more
  energy efficient, offers another
  opportunity for sustainable clean-
  ups. (See Forbes, 2009.) Cleaning
  up contaminated drinking water
  costs more than preventing con-
  tamination in the first place. Addi-
  tional emphasis on preventing and
  detecting small-volume releases
  can better protect water supplies
  and aquatic ecosystems while
  concurrently reducing energy and
  materials use and generation of air

  UST-systems  releases can also
  discharge into surface waters and
  adversely impact sources of drink-
  ing water (as well as ecosystems).
  LID techniques, some of which are
  relatively simple landscaping fea-
  tures, may be  employed to mini-
  mize the amount of contaminants
  washed into surface water bodies
  by stormwater  runoff (USEPA,
  2000a, 2007c;  Pomes,  2008) and
  concurrently  increase ground-
  water recharge.

Measuring Progress Toward
Sustainable Outcomes
Now that we have discussed some
potential opportunities for employ-
ing sustainable practices, what
metrics should be used to measure
progress  toward  sustainability?
There are  two general classes of
metrics that can be considered:
(a)  conventional  metrics  and
                • continued on page 4

LUSTLine Bulletin 62 • August 2009
m Tank Programs and
Sustainability from page 3

(b) "sustainability metrics." Conven-
tional metrics include contaminant
emissions reduced to meet applica-
ble standards, acres of contaminated
sites restored to beneficial uses, and
number of people  protected from
drinking contaminated groundwater.
These metrics are  imperfect for a
variety of reasons. Most significantly,
they tend to be output-oriented, and
it  is difficult to quantify avoided
impacts with any degree of precision
and credibility.
    Sustainability metrics, on the
other hand, are intended to reflect
more broadly the health and well-
being of the system as an integrated
whole. These metrics tend  to  be
outcome-oriented  and include a
wide variety of measures, indices,
and indicators. Linking outcomes to
policies and practices is often diffi-
cult, however. The development of
appropriate, specific metrics requires
collaboration among  state and fed-
eral regulators as the utility of such
metrics  would necessarily reflect
a balancing of what is optimally
desired with what is feasible.
    Sustainable practices with regard
to air and energy are related through
reductions in the generation of GHGs
due to reduced energy usage.  In the
case of air, the impacts are indirect,
but they are direct in terms of energy
use. One measure of reduced elec-
tricity usage would be a reduction in
the monthly electric bill. Electricity
generation statistics can be obtained
or calculated in order  to quantify
reductions in emissions correlated to
reductions in energy consumption.
    Sustainable practices with regard
to land and ecosystems  are related
through the preservation of pristine
land and the reuse of abandoned gas
station properties. Though not tech-
nically difficult to quantify, the first
problem is that there is no national
inventory of abandoned UST sites, so
there are no reliable data regarding
the size of individual properties, how
many there are, or  where they are.
The UST program collaborates with
the federal Brownfields program to
promote and communicate cleanup-
and  revitalization-related accom-
plishments and associated benefits
to society. USEPA has recently issued
guidance on developing inventories
of relatively low-risk  petroleum-
contaminated brownfield properties
to overcome the unique challenges
posed by these sites (USEPA, 2009b).
    Metrics for sustainable practices
with regard to materials are difficult
to identify in a comprehensive man-
ner. UST systems are comprised of a
large number  of components, some
of which are produced by industries
with a large environmental footprint.
Tanks are generally made from either
steel or fiberglass-reinforced plastic.
Pumps  are made of a variety of met-
als. A number of different organic
             Our move
     toward sustainability will
    not happen overnight, but it
 can find a place in our day-to-day
        thinking and even in
          our stated goals.
coatings  and sealants are used to
protect system components and join
them together. Manufacture of each
component could conceivably have
an environmental impact, and deter-
mination of such impacts requires a
life-cycle analysis.
    Sustainability metrics associated
with water resources are also difficult
to quantify as they require a number
of assumptions to estimate avoided
impacts. Though an output and not
an outcome, reduction in the num-
ber of leaks/releases from USTs is
perhaps the most significant measure
with regard to water quality.

Moving Toward Sustainability
Granted, our UST  programs  have
their hands full juggling many com-
peting priorities—budget, financial
responsibility, SPA, leak detection,
corrective action, enforcing regula-
tions, writing regulations, dealing
with legislatures, holding on to staff,
maintaining databases, addressing
training needs...the list goes on. So
our move toward sustainability will
not happen overnight, but it can find
a place in our day-to-day  thinking
and even in our stated goals.
    The concept of sustainability is
extremely broad and complex, so no
one program can address its many
facets. The principal activities/prac-
tices in which our UST programs can
engage to  achieve sustainable out-
comes are: (a) reduce generation of
greenhouse gases by reducing  elec-
tricity consumption through use of
green buildings and green cleanup
technologies, (b) promote reuse of
gas station sites to preserve pristine
land  and wildlife habitat, revital-
ize communities, and restore green
space in urban areas, (c) employ low-
impact development techniques for
management of  stormwater runoff,
and (d) refocus attention on methods
to prevent and detect small-volume
releases to  better protect  water
    The gains from these practices in
the UST program may appear mod-
est at the individual site level, but
there are a large number of such sites
such that in the aggregate meaning-
ful steps toward sustainability can be
achieved. •

  Hal White is an environmental scien-
   tist with USEPA's Office of Under-
 ground Storage Tanks. This article has
 been adapted from a paper he wrote for
  a course in environmental science and
   policy at George Mason University.
 The views herein are the author's alone
 and do not necessarily reflect the views
 of USEPA, and no official endorsement
  should be inferred. Hal thanks OUST
   staffers Robin Hughes and Sharon
 Fredericks for their input, which greatly
 improved the article. Hal can be reached
    via email at

References Cited
Daly, H.E. (1996). Beyond growth: The economics of
 sustainable development. Boston: Beacon Press.
Dellens, A.D. (2007). Green remediation and the use
 of renewable energy sources for remediation proj-
 ects. Available at:
Forbes, R. (2009). Sustainable remediation at the Mas-
 sachusetts Military Reservation. LUSTLine Bulletin,
 60: 4-6. Available at:
Pomes, M. (2008). First green energy gateway fuel sta-
 tion opens in Lawrence, Kansas. LUSTLine Bulletin,
 59: 4-6. Available at:
U. S. Environmental Protection Agency. (1993). Sus-
 tainable development and the Environmental
 Protection Agency: Report to Congress (EPA 230-
 R-93-005). Washington, DC: Office of Policy, Plan-
 ning, and Evaluation. Available at http://nepis.epa.
U. S. Environmental Protection Agency. (2000a). Low
 Impact Development (LID): A Literature Review
 (EPA-841-B-00-005). Washington, DC:  Office of
 Water. Available at

                                                                                      August 2009 • LUSTLine Bulletin 62
U. S. Environmental Protection Agency. (2000b).
 National Water Quality Inventory: 2000 Report.
 Washington, DC: Office of Water. Available at http://
U. S. Environmental Protection Agency. (2004). EPA
 and wildlife habitat council partner to foster reuse
 of abandoned gas stations for parks, wildlife habi-
 tat, and green space  (EPA-510-F-04-007). Wash-
 ington, DC: Office of Solid Waste and Emergency
 Response. Available at
U. S. Environmental Protection Agency. (2005). Every-
 day choices: Opportunities for environmental
 stewardship. Washington, DC: EPA Environmental
 Stewardship Staff Committee. Available at http://
U.S. Environmental Protection Agency. (2007a). Wind
 turbine cost study shows need for  redesigned
 ground-water remediation systems (EPA 542-N-
 06-009). Washington, DC: Technology Innovation
 Office. Available at
U.S. Environmental Protection Agency. (2007b). Solar
 power recirculates contaminated ground water in
 low-energy bioreactor (EPA 542-N-06-009). Wash-
 ington, DC: Technology Innovation Office. Avail-
 able at
U.S. Environmental Protection Agency. (2007c).
 Reducing stormwater costs through low-impact
 development (LID) strategies and practices (EPA
 841-F-07-006). Available at
 nps/lid/costs07/documents/re ducingstormwatercosts.
U. S. Environmental  Protection Agency. (2008a).
 Green remediation: Incorporating sustainable envi-
 ronmental practices  into remediation of contami-
 nated sites. Washington, DC: Office of Solid Waste
 and Emergency Response. Available at http://www.
U. S. Environmental Protection Agency. (2008b). U.S.
 EPA's petroleum brownfields action plan: Promot-
 ing revitalization and sustainability. Washington,
 DC: Office of Underground Storage Tanks. Avail-
 able at
U. S. Environmental Protection Agency. (2009a).
 Underground storage tank program: 25 years of
 protecting our land and water (EPA-510-B-09-001).
 Washington, DC: Office of Underground Storage
 Tanks. Available at
U. S. Environmental Protection Agency. (2009b). (EPA
 510-R-09-002). Washington, DC: Office of Under-
 ground Storage Tanks. Available at http://www.epa.
                  USEPA Region 3  Spearheads  Effort
                to  Develop a Green Cleanup  Standard
     In late 2008, USEPA's Office of Solid Waste and Envi-
     ronmental Response (OSWER) and USEPA Region 3's
     Hazardous Site Cleanup Division (HSCD) and Land
  and Chemicals Division (LCD) set in motion an initia-
  tive to create a Green Cleanup Standard. The effort has
  been taken on by a Green Cleanup Standard work group
  led by Region 3's Deborah Goldblum,  Resource Con-
  servation and Recovery Act Revitalization Coordinator,
  and Kristeen Gaffney of the Brownfields and Land Revi-
  talization office. The group is tasked with developing a
  cleanup standard and verification system that promotes
  more sustainable cleanups at contaminated sites.
     The standard would establish a uniform approach,
  with incentives, to encourage property owners, regula-
  tors,  responsible parties, developers, and communities to
  use green cleanup practices during project planning and
     "We want to develop an 'umbrella' green  cleanup
  standard that could be applied to all of EPA's  cleanup
  programs including storage tanks, brownfields, federal
  facilities, RCRA, and Superfund," says Goldblum. "Hav-
  ing one standard regardless of program or region should
  make green cleanups much easier to implement."
     Sustainable benefits anticipated  for the green
  cleanup standard may include:

  • Minimizing total energy use and maximizing use of
    renewable energy

  • Minimizing air pollutants and greenhouse gas emis-

  • Minimizing water use and impacts to water resources

  • Reducing, reusing, and recycling material and waste

  • Protecting land and ecosystems.

     So far, the group has worked to identify potential
  benefits of and incentives for green  cleanups,  develop
  core  elements, and identify a standards  organization to
  work with USEPA.  By law, the Agency is encouraged to
  develop standards through a consensus process. In this
  case, USEPA will collaborate with ASTM International
                   to develop the green cleanup standard. An ASTM task
                   group will work collaboratively with USEPA and stake-
                   holders to develop the standard, beginning at ASTM's
                   annual fall meeting in October, 2009.
                       The USEPA work group members have identified
                   several key elements that they agree are important for
                   the standard—it should be flexible (with program or
                   state-specific recognition options); be market driven;
                   require minimal resources; and be transparent, univer-
                   sal, verifiable, and voluntary.
                       USEPA and state UST/LUST programs are explor-
                   ing how such a standard would be applied at LUST sites
                   and what incentives could be established to promote the
                   use of a green cleanup standard.  Goldblum notes that
                   some of the key challenges the group faces in developing
                   the standard include avoiding unintended consequences
                   (e.g.,  a bias toward more passive, protracted cleanups),
                   balancing various stakeholders' needs, defining bound-
                   aries (i.e., cleanup versus reuse), establishing a base-
                   line for measuring improvements, identifying potential
                   incentives and certification prior to completion of a stan-
                   dard, and keeping it simple.
                       In addition to USEPA Region 3 personnel, the Green
                   Cleanup Standards work group includes representatives
                   from all OSWER cleanup programs, USEPA  regional
                   offices, and states. Robin  Hughes is USEPA's Office of
                   Underground Storage Tanks work group member.
                       For more information on green cleanup and the prog-
                   ress of the work group, visit the group's CLU-IN website
                       See also:
                   •  ASTM International
                      CART/WORKITEMS/WK23495. htm

                   •  The Association of State and Territorial Solid Waste
                      Management Officials  has a Greener Cleanup Task
                      Force with papers on green cleanup. (http://astswmo.

                   •  The Sustainable  Remediation Forum's white paper on
                      sustainable  remediation (http://iviviv.sustainable reme-

LUSTLine Bulletin 62 • August 2009
The  Transient Behavior of Water in  Ethanol-
Blended Fuels —  Implications for  Leak Detection
by Kevin Henderson

   Jn recent months, a great deal of
   attention has been focused on the
   compatibility of ethanol-blended
fuels with underground storage tanks
(USTS) and dispensing equipment
in an effort to prevent failures (leaks)
that may result from the use of ethanol.
However, scant attention has been given
to the functionality of the equipment
and methods utilized to detect whether
a leak from these systems has occurred.
While it is clearly desirable to prevent
a leak from occurring in the first place,
it should be equally apparent  that we
need to be able to quickly and accurately
detect such a failure. We are introducing
ethanol, a chemical with very different
corrosivity and solvent properties from
traditional gasoline, into an aging fuel-
storage and dispensing infrastructure
with relatively little compatibility infor-
mation. Seems kind of risky. Shouldn't
effective leak detection be a key com-
ponent of the overall ethanol strategy
for the UST regulator? Therefore, a
holistic approach to the identification
and resolution of any potential issues
that may arise from the introduction of
ethanol-blended fuels into our existing
petroleum storage and dispensing infra-
structure demands that our attention
to leak  detection be commensurate with
that afforded leak prevention.

A Matter of Failed Tank
First, we should make it clear that
in this discussion I am talking only
about tank leak detection—pipe leak
detection is not part of this  discus-
sion. More specifically,  for reasons
described below, I am concerned
about  nonvolumetric ("vacuum")
precision tank-tightness testing and
"in-tank" methods of leak detection.
   Typically,  leak detection,  as
applied to USTs, is thought of as the
ability to ascertain the occurrence of
an unexpected loss of fluid from a
tank. However, another important
aspect of tank leak detection is the
ability to recognize the occurrence
of an unexpected gain of fluid (i.e.,
ingress). When groundwater is above
the bottom of the tank, as is often the
            Detecting Water Ingress with Nonvolumetric ("Vacuum")
                      Precision Tightness Test Methods
                     Groundwater Above Bottom of Tank
   \ Leak above product but _ j :
   ;  below groundwater ~  "
   ; Leak below product _ water
    and groundwater ~ ingress
    Water ingress that occurs above the product level is heard as a drip or flow entering the tank.
             > that occurs beneath the level of product in the tank cannot be he
              be detected by a water sensor placed at the bottom of the tank.
Water ingress that occurs beneath the level of product in the tank cannot be heard and must
case, it is not uncommon for tank fail-
ures to manifest themselves via water
ingress.  So the term "leak detection"
is really  somewhat of a misnomer.
    What we are really talking about
is a breach in the wall of a tank (i.e.,
tank-integrity failure). A breach may
allow the stored substance to leak out
of the tank or it may  allow external
fluids (e.g., groundwater) to enter the
tank. Whether groundwater enters
the tank or the stored substance leaks
out depends on the  physical rela-
tionship between the level of fluid
stored in the tank and the level of the
groundwater outside  of the tank. So
when we say "leak detection," we are
really referring to the ability to detect
a failure of the primary  storage tank
integrity. Nevertheless, since "leak
detection" is more commonly used, I
will use  this terminology when refer-
ring to our  ability to detect a failure
of tank integrity.
    The  transitory behavior of water
in ethanol-blended fuels, which I
will discuss below, is a major con-
cern with regard to leak detection.
Its importance has to do with the fact
that it may not be possible to detect
a tank failure via water  ingress with
ethanol-blended fuels under certain
conditions. Although this is the short
version,  there are quite a few aspects
of this issue that complicate the dis-
cussion. What follows is an attempt
to provide a more complete explana-
                               tion of these circumstances and why
                               we should be directing our attention
                               to this issue.

                               Setting the Stage
                               To keep things simple, I will set a few
                               parameters. First, the ability to detect
                               water ingress is usually  of impor-
                               tance only when water is above the
                               bottom of a single-walled tank. There
                               are some possible scenarios where
                               water ingress could be of concern
                               with double-walled tanks as well,
                               but I will limit  this discussion  to
                               single-walled tanks.
                                  Second, while methods of in-
                               tank leak detection include auto-
                               matic tank gauging, statistical
                               inventory reconciliation, and inven-
                               tory  control/tank-tightness testing,
                               I will focus on nonvolumetric ("vac-
                               uum") precision tank-tightness test
                               methodologies that utilize in-tank
                               water sensors to detect water ingress.
                               [In the next issue of LUSTLine, Mar-
                               cel Moreau will  discuss ATGs and
                               ethanol-blended fuels.] Typically,
                               these methodologies involve the
                               application of a relatively  small vac-
                               uum to the tank ullage (space above
                               the product level).  A microphone
                               is  placed  within the tank ullage
                               and the  test operator listens for the
                               acoustic characteristics of a leak.
                               When groundwater is above the bot-
                               tom of the tank, a water sensor must
                               be placed in the tank.

    There are two scenarios to con-
sider relative to the detection of water
ingress. If the breach is above the fuel
level in the tank but beneath ground-
water, the ingress should be detected
acoustically as a drip entering the
tank. If the breach is beneath both the
product level and groundwater, the
ingress cannot be heard as a drip and
the in-tank water sensor must be able
to detect the water ingress.
    Other factors to consider include
temperature of the fuel, turbulence
within the tank, water saturation of
the fuel, and rate of water ingress. In
order to further simplify this discus-
sion, let's assume the temperature is
a standard 70° F and the fuel blend
initially does not contain any water.
This leaves the percentage of ethanol
in the fuel blend and the rate of water
ingress for discussion.

Ethanol Blend Percentage
How does the  percentage of etha-
nol in the fuel blend affect our abil-
ity  to detect water ingress? While
the problem of being  able to detect
water ingress applies to any ethanol-
blended  fuel (including E10), it is
exacerbated  as the percentage of
ethanol increases. Since water is infi-
nitely miscible  with ethanol, it will
mix with ethanol in the fuel blend
and will not form a layer of "free"
water on the bottom of the  tank as
is typical in tanks that contain con-
ventional gasoline. At some point,
if enough water flows in and mixes
with the ethanol, phase separation
will occur and a layer of ethanol/
water will form at the bottom of the
    How much water can mix with
the fuel before phase separation
occurs? This depends on a number of
factors, the most important of which
is the percentage of ethanol in the
fuel blend. Although it is difficult to
find any  citable references, it is gen-
erally stated that the  percentage of
water that can be absorbed before
phase separation occurs ranges from
as little as 0.5 percent in an E10 blend
to as much as 15 percent in an E85
blend. As the percentage of etha-
nol increases in a blend, so does the
amount of water necessary to cause
phase  separation. If we assume
that we will be able to detect water
ingress once phase separation occurs
(and this may not be a valid assump-
tion in some cases), it then  follows
that it becomes more difficult to
detect water ingress as the percent-
age of ethanol increases.

Rate of Water Ingress
How does the rate of water ingress
affect our  ability to detect water
ingress? Let's  consider the require-
ments for nonvolumetric precision
tightness testing. In order to meet
the performance standard for non-
volumetric precision tightness test-
ing, the federal rules require that the
methodology must be able to detect
a 0.1 gph leak (ingress) with a 95 per-
cent probability. To meet the required
95 percent probability of detection,
most methodologies set the thresh-
old at 0.05 gph. This is a very small
leak rate, but just how much of a leak
does this represent? Translating this
to a rate we can better visualize, a
0.05 gph leak is equivalent to a little
over one drop per second. Another
way to visualize this would be to
consider that it would take 20 hours
for one gallon of water to enter a tank
at the rate of 0.05 gph.
    Most nonvolumetric precision-
tightness-testing methodologies rely
on an in-tank sensor installed at the
bottom of the tank to detect water
ingress that occurs below the prod-
uct level. These in-tank water sensors
operate on the principle that given
sufficient time, enough water will
accumulate on the bottom of the tank
to trigger the sensor if water ingress
occurs during the test.
    Because of several factors that
must be taken into consideration,
the length of the test must be calcu-
lated to allow enough time during
the test for enough water to enter
and accumulate at the bottom of the
tank. Although the length  of the cal-
culated test time varies, it typically
ranges from as little as ten minutes to
as much as one hour or more.
    It is important  to  note that
although only a small volume of
water is needed to trigger the water
sensor, the calculation assumes that
all of the water that leaks in during
the test will remain at the  bottom of
the tank for the duration of the test.
Is this assumption correct?

Transient Behavior of Water
The behavior of water when it enters
a tank containing an ethanol-blended
fuel is very different from when it
enters a tank containing conventional
gasoline. Although scientifically valid
data regarding the exact behavior of
water upon entering a tank contain-
ing an ethanol-blended fuel has been
hard to find, we do know that water
is infinitely miscible with ethanol. If
we assume that the ethanol-blended
fuel does not already contain water,
then we know that small volumes
of water that enter the tank will mix
with the ethanol/fuel blend and will
not exist as "free" water on the bot-
tom of the tank.
    But how  exactly does the water
behave when it first enters the tank,
and how does the mixing then occur?
Anecdotal evidence indicates  that
the water will reside as free water
at the bottom of the tank for a rela-
tively short period of time. After 10
to 15 minutes or so, the water  will
rather suddenly mix with the ethanol
within the fuel blend.
    Given that water will not stay on
the bottom of a tank for more than a
short period  of time before it mixes
with the ethanol/gasoline blend, it
is easy to understand why this raises
concerns with regard to the ability of
leak-detection equipment and meth-
odologies to detect water ingress. In
particular, nonvolumetric precision
tank-tightness testing methods  that
utilize in-tank water sensors must
take into consideration the apparent
10- to 15-minute residence time of
    Since the length of the precision
tank tightness test can be as much
as one hour  or more, it should be
apparent that all of the water in the
tank will  not stay at the bottom of
the tank for the duration of the  test.
Therefore, it appears that this fun-
damental assumption made when
calculating the length of the test time
necessary to conduct a nonvolumet-
ric precision tightness test is suspect.
It does not require a great extrapola-
tion of logic to see how the transitory
behavior of water in ethanol-blended
fuels could also affect in-tank leak-
detection methodologies commonly
in use today.

Transient, Shmansient—
Who Cares?
While the conditions necessary to
completely mask water ingress are
probably uncommon, given the
behavior of water in ethanol-blended

               • continued on page 13

LUSTLine Bulletin 62  • August 2009

Whatlf Methaiiol...?
      Buried in the Waxman-Markey "Clean Energy and Security Act of 2009" (HR 2454), is Section 127, the Open Fuel Standard
      Act. This bill amends the Open fuel Standard for Transportation (Chapter 329, title 49, United States Code). It requires that,
      starting in 2012, 50 percent of new automobiles, and starting in 2015, 80 percent of new automobiles, be flex-fuel vehicles
(FFVs), warranted to run on gasoline, ethanol, or methanol, as well as biodiesel-capable vehicles. This is to break the "Chicken
versus Egg" syndrome, an impasse brought about because car companies don't want to make FFVs until the requisite fueling infra-
structure has been built, and marketers don't want to pay to install fueling facilities for FFVs, because there aren't enough of them
on the road. At present, Waxman-Markey has been passed by the House, but not the Senate, so we don't know whether this provision
will remain in the final bill.
    One New York legislator, Rep. Eliot Engel, stated that he wouldn't have supported the bill if the provision to make vehicles that
could run on methanol was not in it, because the legislation is "not just about reducing emissions" but also curbing our dependence
on foreign oil. ( But in terms of energy security, it is important to
note that our methanol may well come from the Middle East. So, what if methanol were to enter the nation's fuel mix? What if?
The Why and Wheref rom
of Methanol
Methanol can be produced from any
carbon-based source. These sources
include natural gas, coal, municipal
wastes, landfill gas, wood wastes,
and seaweed. Methanol is primarily
produced by steam-reforming natu-
ral gas to create a synthesis gas (com-
bination of hydrogen and carbon
monoxide), which is fed into a reac-
tor vessel in the presence of a nickel
catalyst to produce water vapor and
methanol. A distillation step is used
to remove water from the  finished
methanol. Work is also under way to
make methanol from CO2.
    Most methanol,  a common
industrial chemical, is produced from
natural gas, rather than from bio-
mass. Because its economics depend
on low-priced sources of natural
gas, much of the world's methanol is
produced in the Middle East; in fact,
some plants in North America have
closed.  It's not clear that increased
U.S. methanol demand would be met
by either domestic or nonhydrocar-
bon sources. Hence, methanol's effi-
cacy in addressing energy security or
climate change looks questionable. In
addition, vehicle mileage from meth-
anol is even worse than mileage from
    In a listing of methanol plants
in the world prepared by Jim Jor-
dan and Associates,  there were ten
methanol plants in the U.S. at the
end of 2008. Eight are listed as using
natural gas as a feedstock, and two
list coal as a feedstock. From the list-
ing, it appears that six of the plants
(all using natural gas as a feedstock),
may currently not be operating (the
current capacity is listed as 0). (http://
www.methanol. orglcontentlndex.cfm ?se
    In the Renewable Fuel Standard
subtitle of the Energy Infrastructure
and Security Act of 2007  (EISA),
methanol, if made from organic mat-
ter from renewable biomass, quali-
ties as an advanced biofuel. The new
renewable-fuel standard starts at 9.0
billion gallons in 2008 and  rises to
36 billion gallons in 2022. Starting
in 2016, all of the increase in the RFS
target must be met with advanced
biofuels, defined  as cellulosic etha-
nol and other biofuels derived from
feedstock other than corn starch—
with explicit carve-outs for cellulosic
biofuels and biomass-based diesel.
Advanced biofuel includes "butanol
or other alcohols produced through
the conversion of organic matter
from renewable biomass."
    Even after you modify a car to
run on M50 (50%
methanol, 50%
gasoline) or M85 (85% methanol,
15% gasoline), you can't compensate
for its lower energy content with-
out precluding operation on regular
gasoline. While a car running on E85
typically uses 35-40 percent more fuel
per mile than gasoline, you would
need 75 percent more M85 to go the
same distance, because methanol's
energy content is 25 percent lower
than ethanol's and less than half that
of gasoline. A Ford Fusion FFV that
is rated for a combined city/highway
mileage of 21 mpg would get about

15 mpg on E85 and 12 mpg on M85.
Even with a 17.5-gallon gas tank, the
range on M85 would be barely 200

How  Methanol Was Approved
as a Motor  Fuel
In 1979,  USEPA issued a sub-sim
(substantially similar) waiver for the
use of up to 5.5 percent by volume
of a combination of methanol with
tertiary-butyl alcohol (TEA) in equal
parts. This waiver allowed an  oxy-
gen concentration of about 2 percent
by weight. In  1981, USEPA granted a
waiver for use of ARCO's "Oxinol,"
allowing up to 4.75  percent metha-
nol with an equal amount of TEA,
which provides approximately 3.5-
3.7 percent oxygen. This oxygen level
became the effective limit thereafter.
   USEPA subsequently granted
waivers  to  DuPont Corporation
(1985) and Texas Methanol Cor-
poration (1988) allowing metha-
nol/cosolvent combinations up to
3.7 percent oxygen and  including
ethanol as  a  cosolvent alcohol, in
addition  to higher alcohols already
allowed. Several applications  for use
of higher concentrations of methanol
and cosolvents have been denied by
   In the mid 1980s, ARCO  under-
took the only serious effort at mar-
keting methanol blends in the U.S.,
using its Oxinol mixture  of metha-
nol and TEA. It used the Oxinol in
some  of its own gasoline and  also
marketed it to independent retail-
ers and blenders. However, many of
those independent customers subse-
quently discontinued purchase of the
Oxinol, citing reports from custom-
ers of phase separation and/or dam-
age to elastomers and other  real or
perceived problems. ARCO discon-
tinued marketing Oxinol sometime
around 1986. In 1989, USEPA made
a ruling  on fuel volatility,  which
allowed for a 1 psi  differential for
ethanol blends, but not for metha-
nol/cosolvent blends, putting meth-
anol blends at a major disadvantage,
a possible death knell.

The California Methanol
In 1981,  Ford delivered 40 dedi-
cated methanol-fueled Escorts to Los
Angeles County. Four refueling sta-
tions were installed  throughout the
county. The 200-mile  driving range of
these vehicles made it clear that four
stations were inadequate to cover
the requirements of the county. But
the drivers loved the performance,
offering 20 percent more power than
similar gasoline-powered cars and a
15 percent improvement in fuel effi-
ciency. These were cars designed to
run only on methanol, not on blends,
so they were optimized for mileage
with methanol. They would currently
be considered Alternative Fuel Vehi-
cles, rather than FFVs. That was one
of the  problems with them—there
were so few fueling locations, and
they wouldn't run on anything else.
In addition, the vehicles were able to
meet the air-emission standard for
NOx, which gasoline vehicles hadn't
been able to achieve.
   / guess you have to sit down and
   compare all the pros and cons for
   methanol. What will the costs he
   to make the fuel-distrihution and
   storage infrastructure compatible
   with methanol? What happens... ?
    Based on the success of these
vehicles, California asked for several
hundred more, which were delivered
by Ford in 1983. The compression
ratio was increased to 11.8:1, which
provided the increase in power, and
the fuel tank was increased to pro-
vide a driving range of about 230
miles. To fuel the vehicles, California
installed 18 additional fueling loca-
tions throughout the state. This num-
ber of stations was totally inadequate
for the area covered, and drivers had
to carefully plan their routes and con-
stantly monitor their fuel gauges.
    In 1982, Ford began develop-
ment of the flexible-fuel vehicle as a
solution to the fueling-infrastructure
problem. These vehicles had higher
performance when running on meth-
anol, but they could also be run on
gasoline. This technology was seen
as a way  to bridge the gap while
the methanol-refueling infrastruc-
ture grew. However, with the intro-
duction of reformulated gas in the
late 1980s, the air quality benefits
of methanol over gasoline  became
smaller. Following Desert Storm in
1991,  complacency over future oil
supplies grew, and energy security
was no longer a big driver.
   Today, the momentum of the
FFV program has focused on the E85
version. Ethanol has its large base of
support in the farming community
and has a government subsidy for
part of its costs. In addition, ethanol
FFVs receive large credits through
the federal CAFE program.

Health and Safety Issues
Methanol is a more  difficult fuel to
handle than either gasoline or etha-
nol. Methanol is toxic to humans. It
is a neurotoxin. Ingestion of even a
small quantity can produce blindness
or death.  Siphoning fuel  contain-
ing methanol, as is sometimes done
in emergencies, is a no-no.  Labeling
should not use the word "alcohol,"
as this may encourage drinking the
methanol. Methanol can be absorbed
through the skin and its odor thresh-
old is high enough that you can be
exposed to unsafe levels of vapors
without knowing it. If it catches fire,
the flame is nearly invisible.
   According to a 2001 Statoil report,
there are about 35,000 cases per year
in the U.S. of accidental ingestion of
gasoline, mostly  due  to siphoning
by mouth,  (
tox_rev.pdf) The lethal dose of metha-
nol in humans is 25 to 90 mL (in a 70
kg body). The corresponding dose
of gasoline is approximately 400
mL. Ingestion of 400 mL of gasoline
is a very unlikely event, whereas a
mouthful of methanol  may cause
severe toxicity in some individu-
als. Methanol is readily absorbed by
ingestion, inhalation, and skin expo-
sure. Shortly after exposure, it causes
a temporary effect on the brain, simi-
lar to but weaker than that of ethanol.
The more severe, detrimental effects
are delayed and are mainly caused
by the toxic metabolite formic acid.
In severe cases, methanol poisoning
may lead to permanent blindness or
   A study by the U.S. National
Capital Poison Center suggested that
"A comparison of methanol and gas-
oline fatality rates reveals a 25 fold
greater fatality rate for methanol.
From a public health vantage, the
acute hazard posed by  conversion
to methanol-based fuels is unaccept-
able unless appropriate measures
               • continued on page 10

 I What if Methanol? from page 9
are taken to prevent the predicted
increases in fatalities, blindness, and
permanent neurological disability."
(Concawe, 2995  Alternative Fuels in
the Automotive Marketplace,  Report
    The odor  threshold  of metha-
nol may vary from 100 to nearly
6,000 ppm. Assuming that an aver-
age value of 2,000 ppm  is correct,
it would be possible for people to
              Small amounts of water can be car-
              ried away and burned in the engine.
              If larger amounts of methanol are
              present, more water can be absorbed,
              and the components may phase-
              separate. The separation of the com-
              ponents may be prevented by the
              presence of small amounts of higher
              alcohols (e.g., propanol, isobuta-
              nol) in methanol fuels. It is actually
              cheaper to produce methanol with
              these  other alcohols in it, and plant
              output is increased significantly.
   porting methanol as ethanol, with
   the addition of potential material
   compatibility. In addition, com-
   patible storage tanks need to be
   available to store large amounts of
   methanol at the destination.

   Storage  Methanol  must  be
   stored in appropriately designed
   tanks. To limit moisture infiltra-
   tion, a conservation vent with a
   flame arrester is recommended,
   or nitrogen blanketing. Proper
  Table 1.
Exposure Limits for Ethanol and Methanol at ACGIH, NIOSH, and OSHA
              Exposure Limits for Ethanol
 Exposure Limits for Methanol
 American Conference of Government
 Industrial Hygienists (ACGIH)
            1000 ppm threshold limit value (TLV)
200 ppm TLV; 250 ppm STEL; skin - potential
for cutaneous absorption
 National Institute for Occupational Safety
 and Health (NIOSH)
            1000 ppm time-weighted average (TWA); 1900
            mg/m3 TWA; 3300 ppm immediately dangerous
            to life or health (IDLH)
200 ppm TWA; 260 mg/m3 TWA; STEL skin
200 ppm; 6,000 ppm IDLH
 Occupational Safety and Health
 Administration (OSHA) -final permissible
 exposure limits (PELs)
            1000 ppm TWA; 1900 mg/m3 TWA
200 ppm TWA; 260 mg/m3 TWA
be exposed to concentration values
well above the occupational expo-
sure limit value without noticing
(US Department of Transport 1995).
However, the addition of an odorant
to the fuel may help in detection of
spills and minimize exposure. (See
Table 1.)
    USEPA has not established an
MCL for methanol, although it has
set a Reference Dose (RfD) of 0.5 mg/
kg/day. An estimate of an MCL can
be derived from this RfD by using a
formula that accounts for the typical
weight of an adult and a typical daily
amount of water consumption. If this
formula is applied using the RfD for
methanol, a maximum concentration
of 3.5 mg/ L is obtained.
    It has been suggested that addi-
tives could be used to address several
safety concerns related to the use of
methanol. Chemicals could be added
to increase the visibility of flames
from methanol, bad-tasting chemicals
could be added to reduce the pos-
sibility of ingestion, and a colorant
could be added to help  distinguish
methanol from other liquids (Mal-
colm Pirnie, 1999). (http: I I www.metha-

Phase Separation
Gasoline containing 10 percent meth-
anol will absorb 0.1 percent water—
ten times as much as gasoline alone.

              All of the waivers that have been
              granted for use of methanol in gaso-
              line have required that methanol be
              accompanied by a higher alcohol for
              this reason.

              Materials Compatibility
              Lead, tin, and magnesium can be
              attacked by methanol, but there
              shouldn't be any parts of these met-
              als in the combustion zones of an
              engine. Iron and steel are immune, as
              are brass and bronze. Gasoline tanks
              are sometimes made of "terne plate,"
              sheet steel  coated with lead to pre-
              vent water in gas tanks from rusting
              the tanks. But the methanol slowly
              dissolves the lead, causing a sludge
              that clogs fuel filters. When starting
              to use methanol,  the filters should
              be checked and replaced frequently,
              and the lead will be gone in a week
              or two. A solution is for automobile
              manufacturers to abandon the terne
              plate for an epoxy-coated lining in a
              plain steel tank.

              Infrastructure Impacts
              The use of methanol as a transporta-
              tion fuel would have infrastructure
              impacts in a number of areas:

              •  Distribution  Methanol is typi-
                 cally shipped  via  railroad  car,
                 barge, and tanker truck, depend-
                 ing on volume and distance. The
                 same issues are involved in trans-
   grounding is essential, given the
   low conductivity of methanol.
   Tanks may be made of stainless
   steel, carbon steel, or methanol-
   compatible fiberglass. In the U.S.,
   methanol tanks placed under-
   ground must  have  secondary
   containment because methanol
   is classified as a hazardous sub-
     At service stations, a conserva-
 tion vent with a flame arrester is
 used rather than a nitrogen blanket.
 The vent  operates when the pres-
 sure in the tank exceeds a threshold
 value or when the vacuum exceeds
 a specific value. This is especially
 important when storing neat metha-
 nol, since the vapor space in the tank
 will be flammable, unlike storage of
 gasoline or  M85, where the vapor
 space will be too rich to be flamma-
 ble. The lower explosion limit (LEL)
 for methanol is 6 percent by volume,
 and the upper explosion (UEL) limit
 is 36 percent by volume.
     Within the approximate temper-
 ature range  of 12°C to 41°C, metha-
 nol will produce a concentration of
 vapor that is explosive upon contact
 with an ignition source.

 • Service stations  At service sta-
   tions, the submersible  pump as
   well as the piping must be made
   of  materials  compatible with
   methanol. Like tanks, piping can
   be made of stainless steel, carbon

                                                                                 August 2009 • LUSTLine Bulletin 62
  steel,  or methanol-compatible
  fiberglass and, like tanks, must
  be double-walled or have second-
  ary containment. All connections
  must be methanol-compatible. All
  dispenser parts must be methanol-
  compatible, and filters should
  be finer than for gasoline fuels to
  capture  any corrosion particles
  that may occur. All leak-detection
  equipment must be certified for
  use with methanol.

• Other infrastructure concerns
  How many different fuels  will
  stations need to  supply?  EO,
  E10, E15, E85, M10, M85? Regu-
  lar, Midgrade, Premium grades
  of some of these fuels? There is
  a limited  amount of space for
  underground  storage tanks at
  retail facilities. Even with blender
  pumps, picture the maze of piping
  that would be required  to supply
  all of the possible combinations!
  How many dealers want to spend
  the money required to add yet
  another  type of fuel at their sta-
  tion, particularly when E85 hasn't
  exactly taken off in popularity?
  Who gets stuck with the liability
  when  vehicles are accidently or
  inadvertently misfueled? Or mis-
  fueled because ethanol currently
  costs about $2/gallon and meth-
  anol is  currently about $0.75/
  gallon. Even with the mileage dis-
  advantage of methanol,  if the sale
  price is lower, customers may be
  tempted  to fill up  with it anyway.

Methanol Use in FFVs
Relatively few changes are  needed to
change a vehicle into a FFV. An alco-
hol fuel sensor is used to monitor the
fuel mixture and signal the onboard
computer to adjust the fuel flow and
spark timing (current ethanol model
FFVs have  eliminated  the  sensor,
performing that task with software).
Larger fuel injectors are used  to com-
pensate for methanol's lower energy
content to  assure that the same
amount of maximum engine power
is produced.
    Because methanol is corrosive,
certain  metals and elastomers are
avoided, and fuel tanks are nickel-
plated or stainless steel, Teflon or
stainless steel fuel lines are used, and
methanol-compatible elastomers are
used. An anti-siphon neck is installed
in the fuel-filler neck, and an enlarged
carbon canister reduces  evaporative
emissions when commingling occurs
in the fuel tank. To enable the vehicle
to also run on gasoline, the engine
has not been modified to achieve the
power and efficiency of vehicles that
can run  on methanol only.
    Existing engines can be con-
verted  to use pure methanol by
decreasing the  ratio of air to fuel con-
sumed from  about 14 for  gasoline to 6
for methanol by recycling more heat
from the exhaust to the carburetor
and by providing for cold starts. For
methanol, a higher compression ratio
(or variable  compression ratio) and
fuel injection is needed.  It is  unclear
whether all existing E85  FFVs would
be capable of running on M85, but I
doubt that the warranty is currently
written for M85.

Fate and Transport of
Methanol  in the Environment
Methanol is completely miscible in
water; pure  methanol yields a satu-
ration concentration of 792,000 mg/
L. Following a spill, methanol will
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LUSTLine Bulletin 62 • August 2009
Biodiesel:  A Multimedia Evaluation Case  Study
Learning to Play Well with Others When the Ground Rules Change
by Robert Hodam

      California statutes require new
      fuels  and fuel  additives to
      undergo a multimedia evaluation
prior to receiving regulatory approval by
the Air Resources Board of the Califor-
nia Environmental Protection Agency.
(See  LUSTLine #62, "MtEE? Never
Again!") The California Air Resources
Board (CARB) chairs a Multimedia
Working Group  (MMWG) within
CalEPA comprised of the Department of
Toxic Substances Control, the Office of
Environmental Health Hazard Assess-
ment, and the UST Program of the State
Water Resources Control Board  (State
Water Board). Normally, the applicant
is a prospective producer of a fuel or
fuel additive. Normally, the  applicant
finances and conducts testing at the
direction  of the MMWG, which then
reviews the applicants work.
   Long before biodiesel came along the
MMWG adopted a Multimedia Evalu-
ation Guidance Document that sets the
ground rules for the process, which are
normally followed closely. However,
biodiesel changed the ground rules.

Changing the Ground Rules
The first departure from the ground
rules was the fact that there was no
industry applicant. The biodiesel
"industry" collectively has  included
backyard biodiesel chemistry proj-
ects and independent but small refin-
ing facilities using waste vegetable
oil and animal fats, as well as biodie-
sel produced at larger refineries in
the Midwest. By mid 2007 biodie-
sel and biodiesel/petroleum-diesel
blends were being sold, albeit at a
small scale, at various retail,  com-
mercial fleet, and military facilities
statewide without all the appropri-
ate regulatory approvals. Conse-
quently, because no representative
of the biodiesel industry came for-
ward as an applicant for a multime-
dia evaluation, the MMWG chose to
assume the role of applicant in order
to accommodate the public interest
in biodiesel availability.
   The second ground-rule change
was  the  source  of financing. For
biodiesel, the state assumed the cost

of the multimedia evaluation that
would otherwise be borne by  an
industry applicant. State financing
meant the evaluation was operating
under a much more limited budget
than normal.
    By taking on the role of appli-
cant, the MMWG was also on new
ground in terms of the relationship
between its members. For example,
the MMWG was no longer just a pas-
sive reviewer of an applicant's data;
it was now also an active manager of
the process responsible for develop-
ing the data it would review. Lacking
the internal resources to fill the statu-
tory requirement for a three-tiered
multimedia evaluation, and  con-
cerned about an apparent conflict of
interest, the  MMWG hired the Uni-
versity of California (UC) to conduct
the Tier I literature search and to
design and execute a Tier II Experi-
mental Plan to fill the  data gaps in
the literature search.

The Importance of Playing
Well with Others
UC designed the Tier II experiments
to include extensive air emission and
water quality testing. Since this was
the first time the MMWG had man-
aged the Tier II experimental design
process in-house, our respective new
roles were at times somewhat less
than coordinated—and coordina-
tion is the operative word in a multi-
agency multimedia evaluation!
    In this case, for example, hun-
dreds of gallons of soy and animal-
fat-based  B100  test  fuel  were
purchased directly from two manu-
facturers for use in the air emission
testing, but without adequate con-
sideration of testing requirements for
material compatibility, fate and trans-
port, biodegradability, and aquatic
toxicity. In addition, antioxidants
were added to virtually all of the soy
and animal-fat biodiesel—not a good
idea, as it turned out.
    This caused two problems. First,
some of the MMWG were interested
in testing "real-world" samples (i.e.,
biodiesel stored in and  dispensed
from a UST). The thinking was that
"unadditized" biodiesel stored in
and dispensed from a UST might bet-
ter represent the fuel actually used in
vehicles. However, once the fuel was
purchased directly from manufac-
turers and "additized,"  the option
of testing "real-world" samples was
effectively foreclosed for budgetary
    Second, initially there was not
enough fuel set aside to test other
parameters (i.e., material compatibil-
ity, fate and transport, biodegradabil-
ity, and aquatic toxicity tests) besides
air emissions requirements.
    This kerfuffle happened because
the MMWG had taken on the unfa-
miliar role of applicant, and because
we were financing the evaluation on
our own nickel with no room for cost
overruns—because as everyone east of
the Sierras knows, the State of California
has no extra nickels!

Current Status  of the
Biodiesel Multimedia
The Tier I literature search covering
air emissions, aquatic toxicity, fate
and transport, and biodegradability
has been published: California Biodie-
sel Multimedia Evaluation Tier I Report
dia/mu Itimedia. htm).
    Despite the confusion at  the
beginning, the Tier II experiments
are nearing completion using only

                                                                                  August 2009 • LUSTLine Bulletin 62
the "additized" fuel samples and
stretching the fuel supply by drop-
ping the material compatibility test-
ing. UC Riverside has completed the
air emissions testing, and the marine
and freshwater toxicity tests were
recently completed at UC Davis.
   The initial air emissions indicate
higher NOx and CO2 with B20, B50,
and B100 compared with ultra-low
sulphur diesel (CARB diesel). The
initial aquatic toxicology test results
indicate that both soy and animal-fat
B20 are significantly more toxic than
ULSD for all six species of organisms
   However,  in  both cases the
"additized" biodiesel  contained
the antioxidant "Bioextend" (TBHQ,
tertiary butylhydroquinone);  con-
sequently, the  extent to which the
TBHQ additive affected the outcome
is not clear. Because the biodiesel test
samples contained  TBHQ, we have
no way of knowing whether the tox-
icity is the result of a combination of
or the B100 alone. Consequently
the entire  aquatic toxic tests are
being repeated with "unadditized"
B20+ULSD and B100 alone, although
as of this writing we aren't sure how
we're paying for it.
   The next  steps are the Peer
Review of the Tier III Report drafted
by the MMWG followed by  a sub-
mission of the findings and the Tier
III Report to the California Environ-
mental Policy  Council  for a deter-
mination of whether there are any
"significant" adverse impacts that
may affect the transport, storage, and
use of biodiesel as a motor fuel in

Lessons Learned
One test of any procedure or process
is its ability to adapt to unusual situ-
ations. The MMWG was able to do
that, despite a few missteps.
    Lessons learned include:
• It makes sense and saves cents to
  require the producer of the fuel
  product to conduct and finance the
  required multimedia evaluation.

• Avoid, if  possible, conducting a
  multimedia evaluation in-house;
  but if the evaluation must be con-
  ducted in-house, pay close atten-
  tion to coordinating activities
  when differing testing  protocols
  are required. In our case, the entire
  toxicity testing had to be repeated.
  Both composition and quantity of
  B100 was inadequate due to inter-
  nal miscommunications.

• The multimedia-evaluation pro-
  cess works, despite a kerfufflesque
  learning curve due to ground-rule
  changes. •

  Robert Hodam is a chemical engineer
 with the UST Section of the California
 Water Resources Control Board. He is
  currently responsible for alternative
  fuels issues and represents the Board
  on the CalEPA Multimedia Working
 Group. He can be reached at rhodam@
• Water in Ethanol-Blended
Fuels from page 6

fuels, one has to question if the leak-
detection equipment and methodolo-
gies available to us today are capable
of detecting water ingress at the 95
percent confidence level. Research is
needed to supply the data necessary
to properly evaluate the issues in this
discussion and provide clarity rather
than the murky uncertainty that now
   The increasing use of ethanol
as part of our energy-independence
efforts seems unstoppable for the
foreseeable future. Certainly, energy
independence is a vital concern and
a laudable goal. The purpose of this
discussion is not to cast aspersions on
any leak-detection methodology or to
dissuade the use  of ethanol. Rather,
the intent is to stimulate thought and
foment constructive discussion rela-
tive to  potential issues that may arise
from the introduction of ethanol into
our fuel storage and dispensing infra-
structure. Protection of human health
and the environment from the threat
posed by leaking  USTs through pru-
dent and responsible regulation  to
prevent and detect leaks is in every-
one's best interest. •

  Kevin Henderson  is the UST Compli-
 ance & Enforcement Manager with the
  Mississippi Department of Environ-
  mental Quality. He can be reached at

LUSTLine Bulletin 62 • August 2009
Another  Spill-Prevention  Device!
by Stephen Sturdivant

   In the September 2008 issue of
   LUSTLine, Marshall Mott Smith,
   former administrator of the Flor-
ida Department of Environmental
Quality Storage Tank Regulation Sec-
tion, wrote that currently most UST
leaks originate from the spill-bucket
area where delivery drivers deliver
fuel. Delivery spills are usually small
and  are often considered a normal
part of the fuel-delivery process. But
when spill buckets fail, the spilled
product enters the environment and
can add up  over time—and  clean-
ing it up is expensive. While delivery
spills can happen when the driver
forgets to empty the hose after the
drop, loose connections between the
hose and the fill port are also a com-
mon cause of small spills.
    Loose connections may have sev-
eral causes (e.g., the delivery driver
improperly latches the elbow, worn
assemblies, worn fill-port adapters,
worn rubber  gaskets on the inside of
the delivery hose assembly). Worn
gaskets may become more common
because of the growing use of ethanol
in fuels. Since ethanol might corrode
rubber much faster than petroleum,
the useful lifespan of these gaskets
might decrease. Worn gaskets are sel-
dom noticed.
    When delivery spills happen, the
delivery driver might use spill pads
to soak up the spill. These pads may
require special  hazardous material
disposal, an added expense. If the
spill bucket does not contain debris
and/or  rainwater, the driver may
drain or pump the fuel into the tank.
    However, since ethanol is becom-
ing more common in our fuel, the
introduction of water can cause a
host of problems,  and it is almost
impossible to tell by simply  look-
ing whether the fuel in a spill bucket
has been contaminated with rainwa-
ter, because the ethanol absorbs the
water. Water  combines with the etha-
nol until the  ethanol phase-separates
from the gasoline, and even then the
water is at the bottom of the bucket.
Moreover, conductivity probes have
a hard time differentiating between
ethanol and water. Many ATG probes
can only detect the presence of water

after phase separation has occurred.
Finally, few spill buckets have drain

Spill Buckets Have Issues
While spill  buckets are meant to
capture  small leaks  and drips,
they  have drawbacks  that own-
ers, operators, delivery drivers, and
inspectors should be aware of. For
example, delivery drivers often just
leave spilled fuel in the bucket, and
if the bucket isn't watertight, the fuel
slowly leaks into the environment.
Even if the bucket is watertight, leav-
ing spilled fuel in the bucket can cor-
rode it, allowing leaks. Many spill
buckets fail within a few years and
are no longer watertight. While these
failed buckets may appear to be con-
taining spills, they are  more likely
slowly leaking fuel into the ground
with every delivery. These small, slow
leaks may go undetected for years.
    Some failure points in the spill
bucket may be obvious (e.g., cracks,
tears), but many problems are hard
to see by simply  looking into the
spill bucket, a common practice for
many inspectors. Furthermore, many
allowable tank and piping release-
detection methods will not detect
releases from spills.
    Even when  spill buckets are
liquid-tight and functioning properly,
they must be cleaned periodically.
Unless spill buckets are kept clean
and dry, their contents can't simply
be poured into the tank, as that may
introduce contamination from water
and/or debris. Additionally, spill-
bucket contents such as water, fuel,
or debris may be considered hazard-
ous material and must be disposed
of properly.

The Sleeve
Preventing delivery spills will pre-
vent costly and damaging leaks. One
spill-prevention method involves the
installation of a sleeve that fits inside
the elbow assembly of the delivery
hose and extends into the fill port
transforming the hose end into the
male  end of  the connection, thus
stopping  delivery spills before they
happen. Depending on the manufac-
turer, these sleeves are sold either as
an option for a new assembly or as
an inexpensive retrofit.
    Surprisingly, it seems as though
many fuel distributors and even man-
ufacturer sales representatives are not
aware that such an add-on is avail-
able. One manufacturer told me that
these inner sleeves are seldom sold.
  Figure 1. Two views of an elbow with a sleeve (left) and an elbow without (right)

                                                                                   August 2009 • LUSTLine Bulletin 62
He speculated that drivers, many of
whom are paid by the drop instead
of by the hour, are concerned about
the sleeves being difficult to use and
slowing their deliveries and drop
   I accompanied a delivery driver
with  five of  years experience to
gauge firsthand if these concerns
were valid. The  driver used two
elbow assemblies, side by side, one
with a sleeve and  one without. (See
Figure 1.) I watched the driver hook
up each elbow to a different fill port.
He found no disadvantages to using
the assembly with the sleeve. Han-
dling each elbow required the same
effort, and he found  that attaching
and detaching them to the fill ports
was not a problem.
   I also noted the time it took to
deliver fuel into the tanks for each
elbow. The  diameter of the sleeve
was about the same as the inside of
the elbow, so the sleeve did not inter-
fere with the flow of fuel. Each elbow
delivered the same amount  of prod-
uct, and both drops were completed
at the same time.
   Both spill buckets were empty
and dry before the driver hooked
up. After deliveries I found that the
standard assembly without a sleeve
leaked fuel into the spill bucket. The
elbow with the inner sleeve left the
spill bucket dry. (See Figure 2.)
    So it seems to me that it would
be a good  idea to get the word out
that these anti-spill sleeves exist. Pur-
chasing elbow assemblies equipped
with these sleeves, or adding them as
a retrofit, appears to be a simple and
cost-effective way to prevent deliv-
ery spills  at the source instead of
having to spend time cleaning them
up. I am aware of at least three anti-
spill-sleeve manufacturers: Dixon
Bayco - part # 6200-17 and 6200X-17;
PT Coupling - part UTF40 Anti-Spill
Assy; and Civacon "OPW" - part T88
has the sleeve as an option. •

  Stephen Sturdivani is an engineer in
    the Underground Storage Tank
  program at the U.S. Environmental
 Protection  Agency Region 6 in Dallas.
         He can be reached at

This article was prepared by Stephen Sturdivant as
a result of performing his official duties for the U.S.
EPA. However, it has not been formally reviewed
by the Agency, and it does not necessarily reflect the
views of the U.S. EPA. EPA does not endorse, nor
make any claim regarding the accuracy, validity or
effectiveness of any company, technology, process,
service or product that may be identified in this
article. The effectiveness or appropriateness of any
technology,  process, product or service is the sole
responsibility of the user. This information may not
reflect the most current information.
 Figure 2.    Side-by-side comparison of a delivery with a sleeve (left) and one without.
 Before—with sleeve
                                      Before—without sleeve
 After—with sleeve
                                     After—without sleeve. Notice fuel in bucket
• What if Methanol?  from page 11

and groundwater of electron accep-
tors and nutrients required for the
degradation of gasoline. Therefore a
successful natural attenuation strat-
egy for all constituents may require
that the natural environment be
enhanced with the addition of oxy-
gen, nutrients, or other amendments
to facilitate biodegradation of other
gasoline constituents.
   The  high vapor  pressure of
methanol suggests that soil-vapor
extraction should effectively remove
methanol from  soil,  and  once
extracted, it can be treated using
vapor-phase bioreactors. If the meth-
anol is present in the groundwater at
levels of concern, air stripping is not
likely to be effective due to metha-
nol's low Henry's constant;  however,
heated air stripping can be effective.
   Due to methanol's lack of attrac-
tion to organic carbon, granular
activated carbon will be  ineffective.
Advanced oxidation can be an effec-
tive remedial technology, but costs
may be very high. Also, oxidation
technologies  can lead to  undesir-
able changes in groundwater (e.g.,
bromate from bromide, which is
naturally present in the  water, and
mobilization of metals). Biofilters can
be an effective treatment technology,
but they may not be acceptable for
treatment of drinking water supplies
(Malcolm Pirnie, 1999).

So Is Methanol a
"Good" Fuel?
I guess you have to sit  down and
compare all the pros and  cons for
methanol. What are you  going to
make it from,  imported or  domestic
gas, biomass material? Does it cost
more to produce methanol from bio-
mass,  and if so, how  much more?
Will it run in an ESS-certified FFV,
or do we have to create  a whole
new FFV certification with differ-
ent modifications?  What will the
costs be to make the fuel distribution
and storage infrastructure compat-
ible with methanol? What happens
when it is released to the  environ-
ment, and how  much will  it cost to
clean it up? How much more of a
health and safety problem will it be?
Will we take income from our farm-
ers by possibly taking away from the
amount of ethanol used? Time will
tell	•


LUSTLine Bulletin 62 • August 2009
                       - nically Speaking
                          by Marcel Moreau
                                       Marcel Moreau is a nationally
                                    recognized petroleum storage specialist
                                   whose column, Tank-nically Speaking,
                                      is a regular feature o/LUSTLine.
                                    As always, we welcome your comments
                                     and cjuestions. If there are technical
                                      issues that you would like to have
                                      Marcel discuss, let him know at
          Stage  I  Vapor  Recovery  Is Coming  to  a
                                Station  Near You!
               (Uh oh,  Those Air-Quality Folks Are at It Again)
I   dearly love breathing air, especially
   clean air. And I know full well that
   both air and water are requisite to life
as we know it. But we humans can't seem
to make that connection at the regulatory
level, and history has shown us that the
interplay of air quality and water quality
regulatory efforts has had some prickly
moments. MtBE was our first pain-
ful lesson that what might be good for
air quality might not be at all good for
groundwater quality. Even the current
rush to add  more and more  ethanol to
our motor fuels began as an air-quality
oxygenate option, yet the use of ethanol
fuel blends continues to raise seemingly
endless storage-system compatibility
and functionality issues (e.g., see "The
Transient Behavior of Water in Ethanol-
Blended Fuels..." page 6). Meanwhile,
with little fanfare, the Air Quality folks
at US EPA put into law some new Stage I
vapor-recovery requirements in January

The New Stage 1  Rule
The goal of Stage I vapor recovery is
to capture gasoline vapors escaping
from storage tanks during the fuel-
delivery process (See "A Primer for
the Next Generation of Tank People,"
LUSTLine #61). The methodology is
fairly simple in that the vapors from
both the storage tank and the fuel in
the delivery tanker simply exchange
places. All that is needed is a vapor-
transfer hose  between the truck
and the storage tank, together with
appropriate connections to the stor-
age tank and the truck.
    The new rule applies to fuel
transfers at gasoline-dispensing facil-

ities (GDF) and bulk plants. Unlike
previous rules governing gasoline-
vapor emissions, these rules are not
limited  geographically to regions
with poor air quality. The rule comes
under the National Emission Stan-
dards for Hazardous Air Pollutants
(NESHAP) program and is designed
to reduce human exposure to toxic
gasoline constituents. It imposes
vapor-control requirements at GDF
and bulk plants  nationwide. This
article only discusses requirements
for GDF. USEPA estimates there will
be 14,000 facilities needing work,
with a capital cost of about $75 mil-
lion dollars.
   The rule has three tiers of require-
ments depending on facility through-
put. Throughput is calculated by
adding the amount of all gasoline
products dispensed at a GDF over
a 30-day period. Based on monthly
throughput, the rule requirements
are as follows:

• Less than 10K - good housekeep-
  ing measures such as not spilling
  gasoline or storing it in uncovered

• 10K or over - good housekeeping
  plus a drop tube in the fill pipe.

• 100K  or over - good housekeep-
  ing, plus a drop tube, plus Stage I
  vapor recovery.
   Facilities installed or substan-
tially upgraded after November 9,
2006, should be meeting the appli-
cable NESHAP requirements now.
Facilities already in existence prior to
November 9, 2006, have until Janu-
ary 10, 2011, to meet the applicable
NESHAP requirements. Newly con-
structed or substantially remodeled
facilities must use two-point vapor
Figure 1. Two-point Stage I vapor recovery
requires two separate openings into the tank.
In this photo, the hose on the left is for prod-
uct, the one on the right is for vapors.

recovery. (See Figure 1.) Facilities in
operation prior to November 9, 2006,
may retrofit Stage I vapor recovery
using a coaxial drop tube.
   The NESHAP regulations have
some very specific requirements for
the  Stage I hardware that must be
installed, including:

• Pressure/vacuum vent caps

• Fill and vapor adaptors that can-
  not be loosened or overtightened
  during normal operation

• Tightly sealed fill caps

• A sealed vapor path, whether two
  point or coaxial, such that vapors

   do not escape when the cap is

    The NESHAP rules also spec-
ify that  the  storage system pass
a  pressure-decay test  and that
pressure/vacuum vent valves be
tested for proper operation every
three years.  The test procedures
specified are  based on those devel-
oped by the California Air Resources
Board. One of the requirements of the
pressure-decay test is  that the fill and
vapor caps be removed while the test
is conducted. As we'll see below, this
requirement has interesting ramifica-
tions for some of the equipment and
procedures that UST regulators are
familiar with.

Stage 1 Vapor  Recovery and
UST Systems
So how will  these measures inter-
act with existing equipment and the
day-to-day operation  of our UST sys-
tems? Let's have a look:

• Drop Tubes
Drop tubes are typically long alu-
minum tubes that slide down inside
the fill pipe and extend to within six
inches of the tank bottom. With an
installed drop tube,  fuel enters the
tank below the  existing liquid level,
thus eliminating the  splashing that
would occur  if  the fuel were to fall
from the top of the tank down to the
surface of the  liquid. Eliminating
the splashing reduces the amount of
vapors that are  generated. As a side
benefit, drop  tubes also increase the
speed at  which the fuel flows, thus
shortening the  delivery time. Drop
tubes have been in widespread use
for many years  and do not generally
cause any problems in and of them-
selves. The plot  thickens, though,
when other vapor-control compo-
nents, such as pressure/vacuum vent
valves, are added.

• Pressure/Vacuum (P/V) Vent
Traditional vent  caps are  installed
on the top of the vent pipe to both
keep  precipitation out and direct
the vapors that are discharged dur-
ing a delivery upward. Traditional
vent caps allow air  and vapors to
flow freely in  or out of the tank.
P/V vent valves do not allow air and
vapors to flow freely  in or out of the
tank. P/V vent valves are designed
to seal the opening of the vent pipe
and only allow air to flow in if there
is a slight vacuum (between  6.0 to
10.0 inches of water column)  in the
tank, or vapors to flow out if there is
a slight pressure (between 2.5 and 6.0
inches of water column) in the tank.
An inch of water column is the pres-
sure required to support a column of
water one inch square and one inch
high, so the pressures we are talking
about here are quite small.
    The NESHAP regulations have
   some very specific requirements
   for Stage I vapor recovery. Some
     of these requirements have
  interesting ramifications for USTs.
    Like drop tubes, P/V vent valves
have also been in widespread use for
many years. A storage tank equipped
for Stage I vapor  recovery with a
properly functioning P/V valve will
often have a slight pressure inside
the tank. This could be due to a num-
ber of factors, including heating of
the tank ullage during the day, fresh
air coming into the tank during dis-
pensing and expanding as it becomes
saturated with fuel vapors, or simply
the vapor pressure of the fuel itself.
   There is no danger that this
increase in pressure will rupture the
tank, but it causes  some interesting
effects in the fuel inside the drop
tube. Because the drop tube extends
well below the liquid level, the air
space inside the drop tube is iso-
lated from the air  space inside the
body of the tank. The slight pressure
inside the tank created by the P/V
valve pushes down on  the surface
of the liquid in the tank, causing an
upward pressure on the fuel inside
the drop tube. If the fill cap is airtight
(as it is supposed to be), this creates a
slightly pressurized air pocket inside
the drop tube. When the fill cap is
removed, this pressure is suddenly
removed, creating a pressure imbal-
    In this situation the pressure in
the drop tube is equal to atmospheric
pressure, and the pressure inside
the main body of the tank is slightly
above atmospheric. Because of the
very great difference in the surface
area of the fuel in the tank versus the
fuel in the drop tube, the fuel in the
drop tube is pushed upward, per-
haps by as much as several feet.
   The momentum of the fuel mov-
ing up the drop tube causes it to rise
a bit higher than the  equilibrium
point at which the weight of the col-
umn of fuel in the drop tube equals
the pressure inside the tank, so the
fuel falls back down the drop tube.
Because the air in the tank is com-
pressible, the falling product in the
drop tube recompresses the air in the
tank. The net effect is that the prod-
uct level in the drop tube oscillates
on a scale of several feet when the fill
cap is first removed, with the oscil-
lations decreasing gradually so that
the liquid level becomes stable after
perhaps 15 to 30 seconds.
   So here's the rub.  If the fill cap
was  removed in order to take an
inventory measurement and  the
person making the measurement is
not paying attention, the inventory
measurement can be dramatically off
because of the oscillating fluid level
in the fill pipe. Even if the oscilla-
tions have stopped, the fluid level in
the drop tube will be different from
the fluid level in the tank, affecting
the accuracy of the inventory mea-
surements made with a stick.
   The easy answer to this problem
is to drill a  small hole through the
drop tube near the top of the tank so
that the pressure inside the tank and
inside the drop tube can equalize.
But remember that the  fill cap must
be off when the pressure-decay test
to evaluate the vapor tightness of the
tank is conducted every three years.
This  hole will  cause the tank to fail
the pressure-decay test, so it is not
   I expect that in most cases, facili-
ties that  will need to install a P/V
valve will be making inventory mea-
surements with a tank gauge, so this
will not be a major issue because the
effect of the liquid level in the main
body of the tank is very small. But
for folks who occasionally check the
tank gauge accuracy by  making a
stick measurement, this oscillation
of fuel in the drop tube could cause
some consternation.
               • continued on page 18


LUSTLine Bulletin 62 • August 2009
m Tank-nically Speaking
from page 17

• Fill and Vapor Adaptors
That Cannot be Loosened or
When delivery drivers attach their
delivery elbows to the tank-fill adap-
tors, and then attach a 10- to 20-foot-
long hose to the delivery elbow,
they have essentially created a giant
wrench that is clamped on to the fill
adaptor. In the process of adjusting
this hose to make the connection to
the truck, the driver often moves the
hose to one side or the other. Depend-
ing on the direction of the movement,
the fill adaptor that is screwed onto
the top of the fill pipe is tightened or
loosened. The same scenario is true
for the vapor adaptor.
    Next time you find a spill bucket
with a significant quantity of fresh
fuel in it, check the tightness of the fill
adaptor. You may well find that the
adaptor is loose. Loose adaptors that
are not properly screwed  onto the
top of the fill pipe can leak product
into the spill bucket during a deliv-
ery. Both fill and vapor adaptors that
are loose or have been overtightened
so that they do not seal properly can
leak vapors as well.
    Swivel adaptors were developed
to solve this problem. The top part of
a swivel adaptor is designed to rotate
independently of the bottom  part
that is screwed onto the riser. No
matter how much the driver  moves
the hose around, the adaptor remains
liquid  and vapor tight.
    I don't see  any downsides to
swivel adaptors at the moment,
other than that they cost more than
a traditional adaptor, and  the seals
that make the joint between the top
and bottom  of the adaptor  liquid
and vapor tight wear  out, so that
the swivel adaptor will need to be
    A  special tool is required  to
install and remove swivel adaptors,
so that drivers will no longer be able
to use their hoses and elbows  as
wrenches to unscrew a vapor adap-
tor and punch out the ball  of the
ball-float valve that is often directly
below. This will  make it more dif-
ficult  to destroy ball-float valves,
but there are plenty of other ways
that drivers have figured out to get
around ball-float valves.
Figure 2. Coaxial Stage I vapor recovery is easy to ret-
rofit to existing tanks because it usually does not require
breaking concrete. However, because the diameter of the
drop tube is reduced, the delivery flow rate is slower and
the time required to make a delivery is increased.
• Fill Caps That Seal Tightly
Tightly fitting fill caps are a good
idea and are necessary for vapor
control.  Whether more widespread
implementation of Stage I regula-
tions results in a general increase in
the vapor  tightness of our fill-cap
population remains to be seen. Tight
vapor caps do contribute to the fuel
oscillation associated with the drop
tube issue described above.

• Vapor Path Must Seal When Vapor
Cap Is Removed
This is a pretty straightforward issue
for two-point vapor recovery where
vapor adaptors have always had
spring-loaded poppets that seal the
opening into the tank  vapor space,
whether the cap is on or off. But this
requirement also applies  to coaxial
vapor  recovery, which means that
the annulus between the drop tube
and the fill riser must also include
a mechanism to seal  the opening
except when the fill  adapter is con-

• Coaxial Vapor Recovery
Perhaps the biggest issue I see crop-
ping up with the new Stage I rule is
the likelihood that a lot of facility own-
ers will opt for coaxial vapor recovery
for existing facilities. Many of these
tanks will likely have ball floats for
overfill prevention. The addition of
the coaxial vapor recovery essentially
bypasses the ball float so that the new
coaxial drop tube needs to include a
flapper valve as well (unless an alarm
is  installed for overfill prevention)
to meet overfill-prevention require-
ments. (See figure 2.)
    Fortunately, installing the coaxial
drop tube essentially disables the ball
        float, so the ball float will
        not interfere with the opera-
        tion of the flapper valve.
        How does that work, you
        say? Well, let's say we have
        a two-point-vapor-recovery
        system, with a ball float at
        the bottom of the vapor riser
        and a flapper valve in the
        drop tube. If the ball float
        is installed to operate at 90
        percent of tank capacity and
        the flapper valve operates at
        95 percent of tank capacity,
        the ball float will close first,
        thus slowing down the flow
        of fuel substantially.
	      The flapper valve is
        operated by  the rapid flow
 of fuel coming down the drop tube,
 so it will likely have an insufficient
 flow rate to operate properly in this
 two-point Stage  I scenario. With
 a coaxial drop tube, the tank now
 vents through the fill  pipe, so even if
 the ball float closes, it  has no effect on
 the venting of the tank or the veloc-
 ity of the fuel flowing down the drop
 tube, so the ball float does not inter-
 fere with the operation of the flapper
    Because the tank has to pass a
 pressure-decay test with the fill cap
 off, the flapper valve has to be a spe-
 cial model that is reasonably airtight
 in order for the tank to pass the test.
 Installers who are working in parts
 of the country where Stage I vapor
 recovery has not been prevalent may
 need to be reminded that coaxial
 vapor recovery bypasses ball floats
 and that flapper valves need to be
 the airtight.
    So if you're inspecting a facility
 with newly installed coaxial Stage
 I vapor recovery, be  sure you see a
 flapper valve in the  fill pipe or an
 alarm on the wall, otherwise the facil-
 ity will most likely be in violation of
 the overfill-prevention requirements.

 To Learn More...
 For  the full text of the NESHAP
 requirements, go to:
 ttn/atw/area/frlOja08.pdf. The P/V
 vent-cap requirements of the rule
 were amended in June of 2008. The
 amendments can be found at: www.
 For  more  information about Stage
 I vapor recovery, go to www.pei.c
 RP300. •

                                                                           August 2009 • LUSTLine Bulletin 62
from Robert N. Renkes, Executive Vice President, Petroleum Equipment Institute (PEI)
At Long  Last,  Recommended  Practices  for
Marina  Fueling  Systems
        Marina fueling facilities must perform safely,
        reliably, and economically in a very challeng-
        ing environment. Corrosion, ultraviolet radi-
ation, heat, cold, and constant movement—which can
range from a few inches to many feet—each present
engineering challenges that must be understood and
addressed. In addition, marina fueling systems may
have to incorporate design elements to cope with hur-
ricanes, floods, or dramatic water-level changes that
are unusual but foreseeable.
    In the petroleum equipment industry, the typi-
cal fuel-system installation contractor does not con-
struct marina fueling facilities on a frequent basis. As
a result, there is often little
internal company experi-
ence to draw on when a
marina project is under-
taken. My guess is that the
same can be said about tank
    To date, no indus-
try standard exists that
describes how to construct
a marina fueling facility
that is protective of human
health and the  environ-
ment, simple to construct,
easy to maintain, and user-
    PEI  is in  the pro-
cessing of developing a
document (Recommended
Practices for the Installation
of Marina Fueling Systems
PEI/RP1000-09) to provide
a basic reference that con-
veys concrete, authorita-
tive guidance  on how to
deal with the challenges of
constructing safe, environ-
mentally protective marina fueling facilities that will
provide reliable and economical service for  many
years. PEI/RP1000 offers recommendations for materi-
als, designs, and installation procedures suitable for a
wide variety of marine environments, including fresh
and salt water; still  and moving water; and stable,
tidal, and fluctuating water levels. Both fixed, onshore
underground, and aboveground tanks are referenced.
    One of the most challenging aspects of marina-
fueling-system design is the routing of piping between
                      the shore and a floating dock. This portion of the fueling
                      system is especially challenging when the elevation of
                      the floating dock changes significantly due to water-
                      level changes. PEI/RP1000 has separate chapters that
                      describe design factors to consider and recommend
                      materials, valves, fittings, and installation techniques
                      for the fuel piping at:

                      • the shore-to-gangway and the gangway-to-shore

                      • a fixed pier extending out over the water or a wharf
                        or quay paralleling the shore

                      • floating docks.
                     _ Marine Grade Cover
                     Rated for Anticipated Load
    Entry Boot
Example of a diagram from PEI/RP1000-09. The onshore transition sump provides containment and
leak detection for several important components of a marina piping system.
                         The draft document and comment form are avail-
                      able at PEI accepts comments to its
                      draft recommended practices from anyone with an inter-
                      est in the subject. Written comments offering changes to
                      the document must be returned to PEI by September 30,
                      2009, to be considered by  the PEI Marina Fueling Sys-
                      tem Installation Committee. Comments can be submit-
                      ted either online or on the comment form that can be
                      downloaded at the above website. •

LUSTLine Bulletin 62 • August 2009
 Director, USEPA's Office of Underground Storage Tanks

 The  Energy  Policy Act  Is
 Strengthening  UST
 Prevention  Programs
       USEPA, state (including territorial), and tribal under-
       ground storage tank (UST) programs have long realized
       that a significant part of the UST program's success
  hinges on our ability to increase compliance and prevent USTs
  from leaking. When Congress passed the Energy Policy Act
  on August 8, 2005, USEPA, state, and tribal UST programs
  were presented with a mandate that focused  on reducing UST
  releases. The Energy Policy Act contained numerous require-
  ments that fundamentally changed UST programs and gave
  USEPA the authority and new ways to increase  compliance
  and reduce leaks.
      Approximately 50 percent of Americans—99 percent
  in  rural areas—rely on groundwater as a primary source
  of  drinking water. In addition, states report that petroleum
  leaking from underground storage tanks is  one of the major
  threats to our country's groundwater. These facts reinforce
  what has long been a priority for USEPA and state UST pro-
  grams—we need to prevent UST releases.
      August 2009 marks the four-year anniversary since the
  Energy Policy Act became law. In addition,  August 8, 2009,
  is also an important Energy Policy Act deadline:  the require-
  ment to develop state-specific operator training  regulations.
  As I look at what UST programs have done over these past
  four years, I  see much progress in meeting major milestones
  to increase compliance and prevent leaks:
  •   All states and territories have grant agreements in place to
     implement UST provisions of the Energy Policy Act.
  •   56 states  and territories met the two-year inspection dead-
  •   56 states and territories reported on UST compliance in
  •   51 states  and territories posted public records.
  •   42 states and territories implemented additional measures
     to protect groundwater.
  •   37 states and territories have delivery prohibition require-
      I know that the remaining states have also made sub-
  stantial progress in  meeting the prevention requirements.
  States and territories have invested a great deal of energy and
  resources to get this point, and I applaud your efforts!
  Tribal Progress
  Additionally, I  am pleased  to see all that EPA and tribes
  achieved by working together to address tribal-related man-
  dates in the  Energy Policy Act. In August 2006,  USEPA and
  tribes developed a strategy to further enhance our relationship,
  strengthen communication, and further the  goals of the UST
  program in Indian country. The next year, USEPA reported to
  Congress on progress in implementing and enforcing the UST
  program in Indian country. Over the past years,  USEPA and
  tribes have been implementing the goals and objectives of the
strategy. A few of the key accomplishments include: meeting
annually to identify tribal issues, build collaboration, and work
toward continued partnerships; developing federal credentials
for tribal inspectors; establishing a national tribal assistance
agreement to provide tribal governments with  compliance
assistance and training;  and launching a USEPA-based tribal
Web area that provides  information about training, funding,
publications, and regulations. These successes are an impor-
tant component to the tank program's goal of reducing under-
ground storage tank releases.

Industry Cooperation
The prevention provisions of the Energy Policy  Act have an
impact on industry, too.  I commend the underground storage
tank industry (e.g., tank owners and operators, equipment
manufacturers, tank service providers, delivery personnel) for
their support and assistance with USEPA's efforts associated
with the Energy Policy Act. Industry's  real-world  experiences
and input were extremely valuable as USEPA developed the
grant guidelines. I am aware, too, of industry's part in imple-
mentation. For example, I appreciate their creativity in identi-
fying training ideas and approaches for meeting the operator
training requirement. As I see industry's ongoing  cooperation
and support in  meeting the prevention requirements, I appre-
ciate their important role as partners in helping to protect
our land and groundwater from underground storage  tank

The Job Ahead
As we pause to celebrate our accomplishments, we  also  need
to keep sight of the work that still lies ahead. States are facing
an ongoing workload to implement the Energy  Policy Act's
prevention provisions.
    The on-site inspection  requirement is a good example
of the ongoing work states and territories will  continue to
face. They undertook the large  workload necessary to meet
the  initial two-year August 2007  inspection requirement.
Now there's a huge task ahead  to meet the three-year cycle
of inspecting all 235,000 active  UST facilities by August
2010. And the three-year inspection cycle will continue into
the  future. The operator training requirement is  yet another
example of states' and territories' continuing implementation
work. By August 2012, states need to ensure that operators
are trained according to the newly established standards.
    When we add the ongoing implementation work required
by the other Energy Policy Act provisions (e.g., delivery pro-
hibition, public record), I am well aware of how states' work-
load is different today than  it was four years ago.  From our
side, USEPA has worked to provide states and territories with
help in the way of additional resources, such as an increase in
grant funding, USEPA inspections,  and implementation tools.
                                • continued on page 21

                                                                                August 2009 • LUSTLine Bulletin 62
      In addition, USEPA and tribes still have many tasks ahead
  as we continue implementing the tribal strategy's objectives and
  work to further the goals of the UST program in Indian coun-
  try.  Over the  coming years, USEPA and tribes will continue
  our  ongoing work to increase compliance and cleanup  rates in
  Indian country.
      I am quite confident that state, territorial, and tribal UST
  programs, working with the regional UST programs, are up to
  this challenge. I know that together we will continue to make
  strides in keeping our land and groundwater safe from petro-
  leum UST releases.
                      Additionally, I am eager to see whether, as we expect, the
                  Energy Policy Act prevention requirements will result in increased
                  UST compliance and a reduction in releases from USTs. I am opti-
                  mistic that these requirements will assist us in our goal of reduc-
                  ing the annual number of UST releases reported.
                      I greatly appreciate your efforts thus far, and thank all of
                  you who have contributed in so many ways to the success of
                  our efforts in meeting the  UST prevention provisions of the
                  Energy Policy Act.
                      For  more about the UST prevention requirements in
                  the Energy Policy Act, see
                  05.htm m
                   's Official, Hoskinson  Is OUST's New  Dire
  .  -arolyn Hoskinson is now Office Director of USEPAs Office of Underground Storage Tanks. She has been acting in that position
  '  'since February 2009; prior to that she served as Deputy Office Director.
     "I am honored to accept this responsibility and look forward to working with our partners on underground storage tank issues,"
  said Hoskinson.
     Carolyn has been with USEPA's Office of Solid Waste and Emergency (OSWER) for more than 18 years. In 1993, she was
  selected as OSWER's Analyst of the Year and has consistently put those analytical and leadership skills to good use.
     Under her recent leadership at OUST, Carolyn has not only been responsible for leading and overseeing the core program to
  prevent and clean up releases from USTs, but also managing efforts to strengthen UST prevention as required in the Energy Policy
  Act of 2005, revise the I998 UST regulations, and implement the LUST Recovery Act—with associated new policies and unprec-
  edented accountability and transparency expectations.
     Congratulations, Carolyn!
Determining Hydraulic  Conductivity at  LUST Sites
While Conducting Low-Flow  Sampling
by Gary Robbins

   It is almost universal for monitor-
   ing wells at LUST sites to be con-
   structed in a manner in which
their screens and sand packs bridge
the water table. Although position-
ing wells in this manner  may be
useful for mobile product detection,
it makes hydraulic conductivity val-
ues determined from  slug testing
such wells dubious. Twenty years
ago Herman Bouwer recognized
problems that arise owing to backfill
zone drainage in such wells (Bouwer,
   The typical equations for solv-
ing slug tests are based  on log-linear
recovery of the slug (in or out). In
wells that  bridge the  water table,
sand-pack drainage in slug  out tests
leads  to a complex recovery curve
that is multisegmented. The early
segment of the curve is dominated
by backfill-zone drainage.  The late
segment of the curve is dominated
by the development of a  cone of
depression. To solve  for hydrau-
lic conductivity you have to pick
out an intermediate portion of the
curve that you think is representa-
tive of formation recovery. Such a
choice is subjective, and the answer
is very sensitive to where you pick
the curve. Furthermore, sand-pack
drainage requires that the effective
radius of the well is corrected using a
porosity value for the sand pack that
is generally unknown.
   As a means of circumventing
this problem and reducing the need
for an extra phase of investigation,
we came up with the idea of deter-
mining hydraulic conductivity using
the steady-state drawdown and flow
rate achieved during low-flow sam-
pling (Robbins et al., 2009). At steady
state, backfill drainage no longer
occurs. The  method involves using
steady-state versions of the  equa-
tions  used to derive the  slug-test
solutions (Hvorslev or Bouwer and
Rice). The equations can be readily
programmed in a spreadsheet. Since
the method entails using only a sin-
gle pair of parameters, they must be
determined accurately. Check out
our article that appeared in the recent
issue of Ground Water for technical
details at
papers.html. •

Bouwer, H. (1989). The Bouwer and Rice slug test—an
 update, Ground Water, 27, no.3: 304-309.
Bouwer, H. and R.C. Rice (1976). A slug test method
 for determining hydraulic conductivity of uncon-
 fined aquifers with completely or partially pen-
 etrating wells, Water Resources Research, 12, no. 3:
Hvorslev, M.J. (1951). Time lag and soil permeability
 in groundwater observations. Vicksburg, MI: U.S.
 Army Corps of Engineers Waterways Experiment
 Station, Bull. 36.
Robbins, G.A., Aragon-Jose, A. T., and Romero, A.,
 (2009. Determining hydraulic conductivity usin
 pumping data from low-flow sampling,  Ground
 Water 47, no. 2, p. 271-276.

    Gary Robbins, PhD, is with the
 Department of Natural Resources and
  the Environment,  University of Con-
     necticut. He can be reached at:


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A Short History of the NWGLDE
  In this issue's FAQs from the National WorkGroup on Leak Detection Evaluations (NWGLDE), we look back on how the workgroup
  got started back in 1993. Please note: The views expressed in this column represent those of the work group and not necessarily
  those of any implementing agency.
  U  How did the NWGLDE get its start?
  I'-'-  USEPA set a December 22, 1990, deadline that
  required leak-detection equipment (other than interstitial,
  groundwater, and vapor monitoring) to detect 0.1 gph
  (annual test) and 0.2 gph (monthly test) leaks with a prob-
  ability of detection of 0.95 and a probability of false alarm
  of 0.05. The agency also wrote several protocols that man-
  ufacturers could use to prove that their equipment met
  this standard. When Alabama's UST program started
  receiving equipment evaluations, staff members noticed
  that some were not performed strictly in accordance with
  the USEPA protocols. They came to the realization that
  there was no system in place to make sure these evalua-
  tions were performed properly. Therefore, Alabama's UST
  program made it a point to review the  evaluations and
  not allow the use of equipment in the state if the protocol
  was not performed properly. This resulted in the forma-
  tion of a list of Alabama-recognized leak-detection equip-
     It occurred to Curt Johnson, supervisor of the Ala-
  bama UST program at the time, that if other states became
  aware of this same problem, there was the potential that
  50  states would be  reviewing these same evaluations
  and there  could possibly be 50 lists of recognized leak-
  detection equipment! This seemed like a very inefficient
  and potentially very confusing situation. While attend-
  ing a regional USEPA meeting Johnson  approached Lisa
  Lund, then Director of USEPA's Office of Underground
  Storage Tanks (OUST), and presented her with a plan to
  set up a national work group that would review the eval-
  uations and prepare  a list of equipment that was properly
  evaluated and that could be used by all the states. Lund
  liked the idea, and formation of the work group began.
  Curt Johnson and David Wiley of OUST worked out the
  details, such as number of people in the group and mem-
  ber representation.
     At the 1993 Annual UST/LUST National Conference
  in San Antonio, Texas,  prospective members were polled
  to determine the date and location of the group's first
  official meeting. As  a result, the first meeting took place
  in Kansas City, Missouri, on June 4, 1993. This location
  was chosen so that the work group could visit Midwest
  Research and Ken Wilcox Associates, the companies that
  performed the majority of the equipment evaluations at
  that time. During the first meeting, rules  were established
  and the name National Work Group on Leak Detection
  Evaluations was chosen.
     The original work group members were Curt Johnson
  (Alabama), who was and still is the Chair; Lamar Brad-
  ley (Tennessee), current Vice Chair; David Wiley (OUST);
Tony Ritcherson (Alabama); Allen Martinets (Texas);
Russ Brauksiek (New York); Randy Nelson (Region 7
USEPA); Harold Scott (Region 10 USEPA); Beth DeHaas
(Maine); Shahla Farahnak (California); and Mike Kadri
(Michigan). At this first meeting, the list format had to
be determined. California, Region 10 EPA, Alabama,
and  several other states all had lists at that time. The
NWGLDE decided that the California list had the best
format, so with California's blessing, the group began
using the California format and continues to use that
format today.
    Now that it has been 16 years since the beginning
of the NWGLDE, it appears that the concept has been
very successful in providing the leak-detection evalua-
tion  information that USEPA and states need—without
the necessity of every state having to review every eval-
uation. Also, through the years, the group has received
comments from leak-detection-equipment vendors say-
ing that they are very pleased with the concept of the
NWGLDE, because instead of dealing with 50 states on
each leak-detection-equipment issue, they just have to
deal  with the NWGLDE.
    The big challenge of putting together that  first
NWGLDE List  (copies of every edition of the List are
available at of 257 pages is well behind
the NWGLDE.  However, new challenges continue to
arise, such as recent issues associated with the use and
increases in the nonpetroleum composition of alterna-
tive  fuels, innovations in leak-detection-equipment
methods, and changes in state and federal underground
storage tank rules. It appears that the NWGLDE  may
continue to help states address UST leak-detection issues
for many years to come. •

About the NWGLDE
The NWGLDE is an  independent work group comprising ten members,
including nine state and one USEPA member. This column provides
answers to frequently asked  questions (FAQs) the NWGLDE receives
from  regulators and people in the industry  on leak detection. If you
have questions for the group, please contact NWGLDE at questions©
NWGLDE's Mission:
• Review leak-detection system evaluations to determine if each
  evaluation was performed in accordance with an acceptable leak-
  detection test method protocol and ensure that the leak-detection
  system meets USEPA and/or other applicable regulatory perfor-
  mance standards.
• Review only draft and final leak-detection test method protocols
  submitted to the work group by a peer review committee to ensure
  they meet equivalency standards stated in the USEPA standard test
• Make the results of such reviews available to interested parties.

                                                                                     August 2009 • LUSTLine Bulletin 62
                     New  Products from  USEPA's OUST
See OUST's New and Improved
USEPA's  Office of  Underground Stor-
age Tanks (OUST)  has redesigned its
Web home page to  more clearly reflect
program priorities.  Links to information
about preventing releases; cleaning up
releases; biofuels; petroleum brownfields;
and USTs in Indian country  are now more
prominent on the home page and easier
to access. The homepage  is still at the
same address:

Two New Petroleum Brownfields
Products from USEPA
USEPA has  produced two new prod-
ucts devoted to fostering  the reuse of
petroleum-contaminated properties.  One
is a new and more comprehensive web-
site devoted to petroleum  brownfields.
The other is a document,  Petroleum
Brownfields: Developing Inventories,  EPA
510-R-09-002,  May  2009, designed help
to states, tribes, and local areas trying to
create or enhance an inventory of petro-
leum brownfield sites
    The website (
petroleumbrownfields/index.htm) pro-
vides a framework  for the organization
of petroleum brownfields  information.
It is designed to make information more
accessible for those  working to foster the
cleanup and reuse of petroleum-impacted
properties. It provides easy  access to
information  that both new users  and
those familiar with  brownfields will  find
useful. For instance, the site  provides
access to:
•  "How-to" guides
•  Ways to find petroleum brownfields
•  Assessment and cleanup information
•  Financial guides and USEPA Brown-
   fields program and grants information
•  Public/private partnership information
•  Sustainability and petroleum brown-

    The site also  provides "Success
Stories" with links to state, tribal, local,
USEPA, and private petroleum brown-
fields success  stories. The stories are
organized by:
•  State and local area
•  Type of reuse—housing, commercial
   and business, public, and environmen-
   tal and recreational
•  Opportunities  for small  businesses
   —examples  of cleaned up petroleum
   sites where small businesses have been

Petroleum Brownfields: Developing
Inventories (
pbfdevelopinventories.pdf) is intended to
help states, tribes, USEPA Brownfields
Assessment grant  recipients, and others
develop an inventory  of relatively low-
risk, petroleum-contaminated brownfield
properties. The publication has three sec-
• Section I identifies petroleum brownfields
   inventories as a tool for building and
   promoting a brownfields program.
• Section II outlines considerations for
   building an inventory.
• Section III discusses best practices from
   stakeholders that have implemented a
   petroleum brownfields inventory.

OUST Issues Updated Booklet Listing
Insurance Providers for UST Owners
OUST issued an updated version of List
Of Known Insurance Providers For Under-
ground Storage Tank Owners And Opera-
tors, EPA 510-B-09-002, June  2009.
This booklet provides UST  owners and
operators with a list of insurance provid-
ers who may be able to help owners and
operators comply with financial responsi-
bility requirements by providing a suitable
insurance mechanism. OUST periodically
updates this  booklet and makes it avail-
able to stakeholders via its website at:
      ASTSWMO Has a New Web page for Tank Newsletters

  The Association for State and Territorial Solid Waste Management Officials (AST-
  SWMO) has set up a dedicated web page that places state tanks newsletters (and
    LUSTLine, too)  in one centralized location. It can be accessed at http://www,
  astswmo,org/resources_statetanksprograms-tanks_newsletters,html. If you think
  of any newsletters from other tanks program-related organizations that should be
     added to this web page, contact Julius Shapiro at
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                                              LUSTUne fnJe'x

New England Interstate Water
Pollution Control Commission
116 John Street
Lowell, MA 01852-1124
New Class C UST Operator Training Now Online
     Petroleum Training Solutions
     (PTS)  has developed the
     nation's first  online training
course for Class C underground stor-
age tank system operators. A class C
operator is anyone who is employed
at a UST  site whose duties may
include identifying or responding
to an alarm or emergency situation
such as a spill or fire.
    The PTS course, called Fueling
Station Safety, is designed  specifi-
cally for convenience store employ-
ees but is suited for anyone who may
response to an alarm or spill incident
at an UST system with fueling dis-
    Class C operators are required to
be trained in most states by August
2012. In Oregon and California, that
requirement is already in effect. By
the end of 2009, Wyoming and Col-
orado Class C operators must be
trained as well. Utah and New Mex-
ico are also looking to adopt earlier
training deadline.
    PTS created  the course to  fill
the need for Class C training where
UST owners needed a simple, stan-
dardized online solution.
The course takes about
20 minutes and covers
the basics of fueling haz-
ards and emergency and
alarm response. Students
answer a series of ques-
tions, interact with sce-
narios, and take a quiz at
the end. Those who pass
the quiz can print a certif-
icate of completion. User
data and scores are main-
tained in the PTS online
   The course retails for $12.99 per
user. However, the Colorado Wyo-
ming  Petroleum Marketers Asso-
ciations (CWPMA) and the Oregon
Petroleum Association (OPA) have
teamed up with PTS to help sponsor
the course in their states. Members
of those groups get a $3.00 per user
discount. PTS offers bulk discount
for companies with large numbers of
class C operators.
   "Because of the turnover retail-
ers experience with employees, the
Class C operator training will be the
    Fueling Station Safety
    diU C Operator training
most frequently utilized program,"
says Mark Larson, executive director
of CWPMA. "PTS understands this
and has developed a comprehensive,
yet  simple—and almost entertain-
ing—product that anyone can use
anytime, day or night."
    Recently,  Petroleum Training
Solutions launched the nation's first
ever state-approved online operator
training for Class A and B operators
in Colorado. To learn more about the
Class C operator course, go to http://
classc.html •